x

Violating Global Rule 1 and/or engaging in deceptive practices that trick fellow SAG-AFTRA members
into violating said Rule, as well as Rule 18. Additionally, he desecrates the SAG-AFTRA Constitution
Articles II C, D, E, & I generally & Articles II A, B, & III E (2) specifically & cunningly obstructs the
x Union’s effective administration of Articles II H & I

He and his cohorts engage in actions antagonistic to the interests or integrity of the Union pursuant to
Articles II A & B, & Rule 9(C)(2), should it be intended to include live performances not “originating at any radio
station;” but includes those originating from any and ALL sources of medium recordings as it should.

Kevin Hart

9460 Wilshire Blvd. 7th Floor

Beverly Hills CA 90212

(310)

On Wednesday, August 30, 2017, FiCore member, Isaac Clay, with the help of non-union comedic, Arlene Lopez, a.k.a. Lady
Mac, lured Queen Algié Tíye Searles a.k.a., SAG-AFTRA Actress, Queen AllJAHyé, to go on what was supposed to be a “Celebrity
Sightseeing Tour Bus ride around Hollywood for a couple of hours.” They both stated that, not only would she have the opportunity
to network and possibly fulfill her aspirations to be an Entertainment Business Manager, she would be given a $50.00 Cash Stipend.
Kevin Hart, was the only “celebrity” that boarded the bus. Said “Celebrity Tour” turned out to be a mini tour of Hollywood,
promoting neighborhood businesses, including a Dental Office. Prior to coming upon the St. George Dental Office, the comedics
asked who needed dental work as a build-up for their joke and promised to pay for her dental work before Queen AllJAHyé opened
her mouth wide for them to see the dental challenges that she is facing. As they exited the bus Ms. Searles asked who was going to
pay for her dental work and they all joked more as they exited the Bus. She exclaimed to them that she was going to find them,
thinking that she would not see them and that new Celebrities were going to board the Sightseeing Bus. However, just as Kevin Hart
indicated as he got on the bus, he is truly “full of surprises (see video at 1:53).” To everyone’s surprise, after the tour, certain
individuals, including SAG-AFTRA Background Actress, Queen AllJAHyé, were selected to “continue the tour and meet other
celebrities at a special secret location.” The August 30, 2017, “Celebrity tour” with comedians turned into a Kevin Hart, Lions
Gate Television, Inc, Et al. Production of Laugh Out Loud What the Fit, Series 1 Episode 7 produced in collaboration with
Independent Film Channel (IFC), Comedic duo Rhett James McLaughlin & Charles Lincoln Neal III, a.k.a. Good Mythical Morning
(GMM), Commercial Kings, Rhett & Link, and abruptly, without any warning, a 60-minute BENGAY commercial advertisement
was Recorded within the production. Said episode was not published on YouTube until April 19, 2018.
(Continued)
1
 As can be ascertained from an August 4, 2017 DEADLINE article written by Anita Bush,1 Mr. Hart joined forces with LIONS
GATE TELEVISION, INC. in a subterfuge to build a “One Destination For Comedy.” This diabolical UNION Busting ploy,
which is the ‘brain child’ of team Lions Gate Television Inc, and its CEO Jon Feltheimer, is a Cyber Pyramid scheme in a race for
views, subscribers and downloads. It places Lions Gate as top Financer and Hart, as the top comedic Sambo2 and center of focus.
As Hart Explains, Lions Gate finances his productions. He in turn, uses his Fame to exploit, not only his own Brand, his Fans and
their friends; but he extends his exploitation exponentially, including his Famous Celebrity Friends; their friends and Fans; as well
as, other SAG-AFTRA Artists, and especially new Talent; to build a Super Massive Powerhouse Cyber-verse that translates into
mega-millions, maybe mega-billions in monetization, commercials, ads and other miscellaneous perks and streams of revenue.
The Lions Gate and Hart 50/50 Union Busting partnerships are ‘organically’ established only with compatible corporations and
Talent that congeal with their objective to cut the middle man out of the prosperity equation and “break new talent,” unless they
have Hart’s approval and permission, like rising comedic superstar Tiffany Haddish, who appears in Series 1 Episode 3 of the
Lion’s Gate & Hart What The Fit Series, as well as in the BENGAY Commercial portion of the production.
Apparently, the objective of Mr. Hart’s avaricious collaborations and productions, that include but is not limited to his What
The Fit Series, is to build a Mega Cyber-verse viewership incurring minimal expenses by making actors expendable, and
effectively averting SAG-AFTRA Rules, Articles and Governance, as defined in the SAG-AFTRA Constitution. In each of Kevin
Hart’s YouTube, What The Fit Series I Episodes, Hart and his guest wear clothing that promote corporate products, such as
NIKE, promote local Businesses, and almost 30% of said series spotlight Johnson & Johnson’s BENGAY, wherein Mr. Hart and
his guest engage unsuspecting actors in their commercial productions. They blend emerging Actors and talented Background
with their fans and elicit captivating reactions by making false promises and thereafter “Laugh Out Loud” in their faces, while
simultaneously engaging their blindsided groupies to laugh and expecting the actors to laugh as well. Being caught on camera, off
guard and/or not yet realizing that the promises are fake, i.e., ‘Jokes;’ which are actually verbal contracts, most actors stay in
character and go with the flow. It has come to my attention that Mr. Hart and his cohorts produce these series under the SAG-
AFTRA New Media Agreement. This explains why my initial quest to locate the production by contacting Jennifer Matthews in
the Commercials Department returned void. However, it does not explain why she has never responded to my request for her to
find out what productions Kevin Hart was involved with during our discussions.
Accordingly, it is inexplicable that SAG-AFTRA Deputy General Counsel Nicole Nakagawa is of the opinion that the
aforementioned segmented BENGAY “Commercial,” that is produced live and embedded into the Lions Gate Television, Inc and
Kevin Hart Production, What The Fit, is “NOT a Commercial. She and other SAG-AFTRA leaders are categorizing what is
clearly a commercial as an “Ad” that was produced in accordance with the SAG-AFTRA New Media Agreement.” However,
the New Media Agreement explicitly states in substantial part that, “it is not intended to cover and shall specifically exclude…
commercials, or any type of production or medium otherwise covered by any other SAG-AFTRA agreement… It is not intended
to be used to circumvent the terms and conditions of any SAG-AFTRA Agreement or Membership Rule.” Thus, Kevin Hart and
his affiliates violated GLOBAL RULE 1 by performing services for an employer, namely, JOHNSON & JOHNSON, owners of
the product BENGAY, who has not executed a basic minimum agreement within a jurisdiction where there is a SAG-AFTRA
National Collective Bargaining Agreement in place. In addition to defrauding SAG-AFTRA Member, Queen AllJAHyé Searles
and other background actors into participation in a production in violation of aforementioned GLOBAL RULE 1, Mr. Hart and
his team engaged in abominable stratagems using a FiCore member, a non-union member, his fans and others to deceive her and
other SAG-AFTRA Members into violating Rule 18, which states that:
No member shall perform services as a background or extra performer for any production without
coverage of the applicable UNION AGREEMENT in the specific zones as to minimum pay, benefits
and working conditions.
While Complaining SAG-AFTRA Member currently has no way of knowing for sure what other actors on the set of this
production earned, most whom she communicated with thought the production was a “$50.00 cash paying celebrity tour.”
Viewing the video can confirm that this began as a tour and Mr. Hart worked and spoke strategically to not disclose any
information, even saying upon arrival to the production set that, “We’re approaching the thing with the stuff…,” Complainant was
one of the first to stand to see What ‘Thing’ and What ‘Stuff’ Mr. Hart was referring to as he proceeded to ask, “Who doesn’t like
working out in one hundred and 26 degree heat?” Complainant recalls thinking, “I mind, what is he talking about?” At this
juncture, Mr. Hart, his affiliates and producers defile Article II Objective E of the SAG-AFTRA Constitution by involving
members in employment that is in direct opposition with the UNION’s objectives to work in the best interest of members for the
“advancement and improvement of members’ compensation and working conditions.” The New Media Agreement, states that
Background Actors are governed by Schedule X Part I of The Basic Agreement.

1 https://deadline.com/2017/08/kevin-hart-interview-laugh-out-loud-launch-1202142601/

2 https://www.urbandictionary.com/define.php?term=Sambo
(Continued)
Mr. Hart and his cohorts violate several sections of said Schedule X-I as follows:
1. 3 - MINIMUM WAGE SCALES AND HIRING PROCEDURE (a)(1) – Obviating Payment of the minimum wage scales
at the applicable Background Actor Rates by craftily attempting to “cut out the middle man” utilizing Union Busting Tactics
that deceive SAG-AFTRA Members and put them in incriminating predicaments if they choose to expose said deception.
Relative to the charges herein, Fi-core member, Isaac Clay and his friend, rookie comedic, and a fan of Mr. Hart’s, Arlene
Lopez, who also recruited her son, who is a SAG-AFTRA Member; were used to misrepresent the terms of engagement with
the specific intent to deceive SAG-AFTRA Actress, Queen Searles, and possibly other Members into appearing as
background in a production that circumvents the minimum New Media Agreement, as well as the Basic Agreement. His
team elicited desired camera reactions from Queen Searles by agreeing to pay for dental work. Specifically asking, “Can we
get a Clap—a handclap,” (camera flashes to Actress)” which for one who is carrying a Staff and believes that they are going
to be compensated with dental work, equates to ‘Can we get a smile—A big Smile...’ See Supporting video @ 3:15 of
cameraman knowing on which actress to focus. A ploy Hart uses throughout his production, particularly when he promises
$1,000 dollars to the winning team members of his rehearsed portion of Johnson & Johnson’s BENGAY Commercial
wherein he repeats their jingles, “we’re gonna go all in and win…you may be a sore winner, but hopefully, this win from
BENGAY will help relieve the pain” and after the commercial Hart hand’s the BENGAY trophy to elicit more unpaid actor
reactions, then immediately takes it back and tells them they must share the proceeds;
2. 29 - MEAL PERIODS (a)(b)(c)(d) & (e) - Neglecting to provide meal periods and disregarding their responsibility under
these sections to “supply adequate, well-balanced wholesome, nutritious foods.” Notwithstanding that §29(d) states in part
that “whenever Producer supplies meals or other food or beverages to the cast or crew, the same shall be furnished to all
background actors… catering for cast and crew members was supplied by Bruce’s Catering and background actors were not
only not provided a meal by Bruce’s Catering, they were not provided the minimum meal period required by §29(a) nor the
penalty required under §29(e). Further, they were wrapped before being provided a meal period in accordance with
§29(b) nor were they given any non-deductible meal periods provided for by §29(c). According to Ms. Lopez, “as so[on] as
[they] got on the bus, [they] were wrapped and …fed” (See Attachment 2-2).
Ms. Searles was feeling very faint due to the extreme heat and not being supplied with adequate water nor breaks and
requested a meal while on set and was told that they would provide Pizza and Sandwiches on the Bus. Devastated and
appalled, she personally told Mr. Hart, that as she showed them on the bus tour, she was having serious dental issues and
could not eat Pizza and sandwiches, had not eaten all day and that she was feeling faint and needed something to eat
immediately. Glancing up only partially, Hart cut his eyes at the actress so condescendingly, giving her that, “If eyes could
kill” look!!! Then several of Hart’s team members accosted her, not one of them showing any concern for her well-being.
3. 30 - WORK TIME (a) If background actors are first required to report to the studio, work time shall begin and end at the
studio, such work time to include travel time both ways between studio and the Studio Zone location. Mr. Hart and his
production team failed to properly wrap Ms. Searles at the Studio site that was located 1754 N. Orange Drive, Hollywood,
CA 90029 and wrapped the other background actors at the Studio Zone Location, thereby pilfering work time from the
background actors. One of Hart’s crew members agreed to ride back to the location of the Studio with Ms. Searles in an
UBER, however, notwithstanding the Actress’ impending medical condition, once the driver arrived, another dirty trick
was played causing the Actress more undue mental and physical anguish. The driver was given an address either in Corona
or Covina to drop the Actress off, which is 40 to 50 miles in the opposite direction of the Studio Location. Although the
following morning, August 31, 2017 through text messages, Actress Queen AllJAHyé requested the information to locate
the production company to procure appropriate payment for the actual work engagements, as well as payment for her dental
work as agreed to, Non-Union FiCore member, Isaac Clay refused to provide said information replying, “Jesus told me not
to send it to you…” (See Attachment 1-2 #12 & 13). The Actress also attempted to obtain the information from Non-Union
member and Hart fan, Arlene Lopez by phone and confirmed Ms. Lopez denial of having any knowledge of the production
by text message (See Attachment 2-3 col. 2).
4. 44 - POLICY OF NON-DISCRIMINATION AND DIVERSITY (g) – Rather than adhere to the producers’ and their
respective casting agents’ agreement with the Union for the parties “to endeavor to increase work opportunities for
background actors,” Producers, Hart and Lionsgate formed a quid pro quo partnership, with the specific intent of
‘disintermediation’ of the entertainment industry which they unabashedly shared with the public on August 4, 2017 (See
attachment 3). Thereafter they hoodwinked SAG-AFTRA, violated the Union Constitution, misused a “New Media
Agreement,” craftily circumvented SAG-AFTRA authority, and filched actors’ work opportunities by combining three
different engagements into one $50.00 income for actors. The original job, riding around Hollywood on a celebrity tour bus,
wherein various neighborhood entities where advertised, which is a specialty of The ‘Commercials Kings,’ Rhett & Link;
included two other jobs, a Series I Episode 7 What The Fit production and a Johnson and Johnson BENGAY commercial.

(Continued)
3
 5. 45 – SANITARY PROVISIONS (a)(b),(e) & (f) The Lionsgate and Hart Production team failed to adhere to the provisions
of §45(a), they neglected to supply adequate drinking water, as well as §45(b), §45(e), & §45(f); there were no seats,
stretchers and/or cots suitable to be used as a stretcher; when complaining member made it known that she was feeling
faint and famished, she was not offered food or water, but was told that they would be fed pizza and sandwiches when the
production was over and background actors were on the bus. She had to venture away from set to find a shade tree where
she fell to the ground Prayed, rested and began engaging in deep breathing techniques. At no time did any member of the
production team check on her well-being or attempt to provide a means of protection from the sun or any other cooling
methods during the unusual and extreme summer heat as required by the UNION contract. Additionally, member
experienced leakage when she nearly micturated in her attire and was forced to urinate outside, causing her embarrassment
and extreme self-consciousness about reeking with the stench of micturition, as there were inadequate toilet and washing
facilities on location for her to freshen up.
6. 60 – PENSION AND HEALTH PLANS Hart, Lionsgate and his producers’ engagement in the pilferation of Background
Actors proceeds and avoidance of fair payment by misrepresentation of the terms of the agreement from a couple hour tour,
to a production and commercial, obviates payment of applicable Pension and Health Plans for background actors pursuant to
§60 of the Agreement. It prevents Actors from accumulating Pension and Health benefits under the Contract. Hart’s
violation of this section, coupled with the fact that he and his comedic duo, Commercial Kings Rhett & Link, elicited
reactions from SAG-AFTRA Member, Queen AllJAHyé, based on fallacious promises to cover her dental expenses and
thereafter engaged her in hours of onset productions and responded odiously when she requested a meal that would
accommodate her health challenges; rather than cold pizza and sandwiches, which would necessarily exacerbate her
suffering; is a reprehensible blasphemy of the SAG-AFTRA Constitution and the Basic Agreement. Further, it is
disrespectful to the Member, a breach of an implied contract and has caused her humiliation, as well as escalating dental
costs since the time of said breach.
The aforementioned violations by Mr. Hart and his affiliates impede SAG-AFTRA Leadership’s ability to effectively implement
the Objectives of Article II C, Article II H & Article II I of the SAG-AFTRA CONSTITUTION, which are specified as follows:
C. Increasing our power in dealing with the various governmental bodies that
address the significant public policy issues confronting our members;
H. Collecting and distributing government mandated or other compulsory
royalties, levies or remuneration subject to worldwide collective administration;
I. Without limitation, protecting the rights of entertainment and media artists in all other respects
consistent with the overall objectives of the Union and doing all other things necessary
and proper to advance and promote their welfare and interests.
By engaging in any and all of the aforesaid actions and violations, Kevin Hart deliberately disregards Article III E (2) Rights and
Obligations of Members which specifically states:
All members of the Union agree, by virtue of such membership, to comply with the Union and Local
Constitutions, rules, policies and procedures as they exist or are subsequently adopted or amended.
Mr. Hart exhibits gross indifference to the agreement that he entered into and his obligation to abide by such agreement.
His 50/50 joint venture with Lions Gate Television, Inc.; unambiguously defining that their objective is to “cut out the middle
man…break new talent,” and that Lions Gate would finance the productions and Hart would use his fame to exploit fans and other
artists; personify “actions antagonistic to the interests or integrity of the Union.” Moreover, Kevin Hart’s unscrupulous activities
are, encumberments to the Union’s ability to effectuate the Objectives of Articles II, A, B and D which state as follows:
A. Increasing the power and leverage of our members in their bargaining
relationships with the employers in our industries;
B. Organizing workers in the entertainment and media industries in order to
maximize our bargaining strength;
D. Protecting and securing the rights of our members in their professional activities,
including securing meaningful legislation and regulations on matters affecting their work
and taking appropriate protective action in response to the unauthorized use of their work;
Kevin Hart and Laugh Out Loud (LOL) president, Jeff Clanagan’s pact with Lions Gate Television Inc, and its CEO Jon
Feltheimer and their productions, of What The Fit Episodes I Series 3, Series 7, Series 12 and Series 15, is deflective and polar
opposite of the above stated UNION Objectives, making them abhorrently antagonistic to the interests and integrity of the UNION.
This collaboration with Lionsgate substantially reduces the UNION’s bargaining power and leverage on behalf of UNION members,
marginalizing them to positions of servitude and robbing them of opportunities and perpetuities, as well as earnings commensurate
with the engagement that would yield them fair pay, commercial contracts, pensions, royalties, health benefits and other perks that
increase wealth and enhance self-esteem.
(Continued)
4
 Although not listed in (1) or (2) of the above charges against SAG-AFTRA member Kevin Hart, his direct filching of funds and
opportunities from SAG-AFTRA Members through his joint alliances, also indirectly violates SAG-AFTRA Constitution Article II
Objective G which is:
G. Receiving, administering and expending the Union’s funds in the interests of
our members;
Hart and his co-collaborator’s pilferages from the earnings and opportunities of Members not only thwart the UNION’s
objectives to receive, administer and expend funds in the best interest of Members on said filched incomes, they threaten the future
earnings of established actors and sports and entertainment professionals who currently receive endorsements to produce
advertisements and commercials, such as, but not limited to former all-stars Baron Davis and Paul Pierce whose BENGAY
YouTube Sore Winner Commercial was published on March14, 2018 has generated only 2,372 views to date
(https://youtu.be/VogtWbKwATA) and their YouTube TV BENGAY “Sore Winners” Special, published May 14, 2018 only
generated 504 views ( https://youtu.be/pzVkZvi5XI0 ); as compared to the Kevin Hart, Laugh Out Loud, and Lions Gate TV, et.al,
“What The Fit” BENGAY YouTube Sore Winner Commercials, Series 1 Episode 3, Episode 7, Episode 12, and Episode 15, which
to date have generated 9.2, 5.6, 8.2, and 4.9 views respectively, and were produced in conjunction with some of Hart’s good friend,
including Tiffany Haddish, Rhett & Link, Jack Black, Houston Rockets, Chris Paul, and D.J. Khaled. Collectively, and over a
period of time, particularly since on page 4 of Attachment 3, Hart says, “He expects that the company will enter into more
corporate partnerships when and where it works organically.” Hart already has corporate sponsors Lyft as a partner, as well as
NIKE, which he wears in every Episode of his “What the Fit” Commercials. As they engage other companies, and/or as other
companies analyze the data as depicted in the following Chart & Graph, future UNION revenues can be expected to drastically
decline. Additionally, more artists will become FiCore members or remain non-union actors, as the incentives to join SAG-
AFTRA will become less and less appealing. It is critical that UNION Leadership works expeditiously and pertinaciously to close
these technological advancement loopholes that threaten the livelihood of actors and jeopardize the existence of SAG-AFTRA.
BENGAY COMMERCIALS Series 1 Date Published Viewership as of
February 17, 2018
- B. Davis and P. Pierce March 14, 2018 2,372
- BENGAY "Sore Winners" Actors March 14, 2018 3,601
- YouTube Special B Davis May 13, 2018 504
TOTAL SAG-AFTRA COMMERCIAL VIEWS 6,477
Kevin Hart & Lionsgate TV BENGAY COMERCIALS
Tiffany Haddish Episode 3 March 22, 2018 9,202,124
Rhett & Link Episode 7 April 19, 2018 5,601,998
Jack Black & Chris Paul Episode 12 May 24, 2018 8,239,945
DJ Khaled and ‘Kid’ Episode 15 June 14, 2018 4,852,956
TOTAL VIEWS KEVIN HART, Et al. Production 27,897,023

https://youtu.be/0xw8WKRApOk https://youtu.be/VogtWbKwATA https://youtu.be/Kx7UWhycxrQ

5
 K. Roy
UNKNOWN

In addition to the aforementioned violations of several sections of Schedule X-I, Kathleen Ray can provide
information corroborating the facts that Mr. Hart and his team agreed to pay for Queen Searles dental work before
making her the butt of their joke as before they passed the St. George Dental Clinic and that Mr. Hart told the people
participating in the BENGAY Commercial that they would get $1,000 and after the commercial he told them they
would have to share the money:

(2) NAME J. Spio Address UNKNOWN

E-MAIL Phone: UNKNOWN

IMBD WEBSITE
Information witness can provide:
Justin can provide the same information as stated above. Complainant cannot be not sure that these actors were also
paid to participate as tourist on a sightseeing bus for $50.00, Nor if they were aware that this engagement also included
a Production and a commercial and knowingly agreed to participate for $50.00 cash.

(3) NAME Isaac Clay Address UNKNOWN

Phone Number
Information witness can provide:
Isaac can attest to the same information stated above as well as that he stated the engagement was a couple hour tour
around Hollywood on a Tour Bus with celebrities and that a $50.00 cash stipend would be given at the end of the tour.
He can also confirm the text message conversations between him and Queen Searles in Attachment 1 of this document.

(4) NAME Arlene Lopez a.k.a Lady Mac Address UNKNOWN

Phone Number E-MAIL

Information witness can provide:
Ms. Lopez can attest to the same information stated above as well as that she detailed the engagement as being a
couple hour tour around Hollywood on a Celebrity Tour Bus and that a $50.00 cash stipend would be given at the end
of the tour. She can also confirm the text message conversations between her and Queen Searles in Attachment 2 of this
document wherein on December 3, 2018 she finally admits being aware that she knew the engagement was a
commercial. She refused to cooperate in Complainant’s quest to procure information about the production company and
who to request payment from for the three engagements, as well as to requests payment for her dental expenses. Of
these witnesses, she was on the lower portion of the Tour Bus and did not witness the agreement, however, she was told
of the incident and she too began to ‘LOL.’ Which seems to be a comedic game response to opposition to injustice.
6
The following documentary evidence is relevant to the charge (please attach copies if you have or can
obtain same):
(1) Description of document: Attachment 1-1 & 1-2 are copies of text messages between Queen Searles and Isaac
Clay confirming the details of the engagement complained of herein the evening prior to and the two days following the
Tour/Production/Commercial.
Dated: August 29, 2017 beginning at 10:15 PM, August 30, 2017 & August 31, 2017
Facts it will establish: These messages will establish that Ficore member, Isaac clay had devious intent from the onset and
that he adamantly refused to provide any information regarding the event to Complainant and even desecrated the name of Jesus
and attacked Ms. Searles mental stability for asking to be provided with information about the production so that she could
follow-up about receiving payment and most importantly, to have her dental work paid for as agreed.
Available from (if not attached) Attached

(2) Description of document: Attachment 2-1 thru 2-5 are copies of text messages between Queen Searles and Arlene
Lopez confirming the details of the engagement complained of herein the evening prior to and the days following the
Tour/Production/Commercial; as well as subsequent conversations on
Dated: August 29, 2017 at 7:07 PM; August 30, 2017; August 31, 2017; Sunday December 2, 2018, & December 3, 2018
Facts it will establish: That Complainant was devasted at how she and others were treated the mental anguish she
experienced onto turning her children’s Haiku Poetry profane, has relentlessly attempted find the name of the producers and
their contact information. Further it shows that Arlene Lopez and Isaac Clay worked together to cunningly con her into
participation. After she did not respond to Lopez’s email, she received a call from Clay they both knew it was a production and
failed to inform her of the complete terms of the engagement and may have been paid more.
Available from (if not attached): ATTACHED
(3) Description of document: Attachment 3-1 thru 3-5 Online Deadline Article, Kevin Hart On ‘LAUGH OUT
LOUD’ LAUNCH: “ONE DESTINATION FOR COMEDY,” written by Anita Bush.
Dated: August 4, 2017
Facts it will establish: Outlines the details of the Hart, Clanagan, & Lionsgate CEO Feltheimer plan to “cut out the middle
man (SAG-AFTRA, Et al.),” rob new talent & pimp fans in a Pyramid ploy to build a Cyber-verse Empire that translates into
mega-millions, maybe mega-billions in monetization, commercials, ads and other miscellaneous perks for a select few that will
be ‘organically chosen’ like NIKE, Lyft, BENGAY, Tiffany Haddish, Chris Paul, and Independent Film Channel (IFC),
Comedic duo Rhett James McLaughlin & Charles Lincoln Neal III, a.k.a. Good Mythical Morning (GMM), Commercial Kings,
Rhett & Link.
Available from (if not attached): ATTACHED and at https://deadline.com/2017/08/kevin-hart-interview-laugh-
out-loud-launch-1202142601/

(4) Description of document: K. Hart BENGAY Video with a series of Captioned Screen Shots and commentary
inserted by Complaining Member that Support allegations that the video in question, What The Fit Series 1 Episode 7,
as well as Episodes 3, 12, and 15; are Johnson & Johnson BENGAY Commercial Productions. Member should be paid
accordingly.
Dated: February 19, 2018
Facts it will establish: It establishes that said production did begin with a Tour for which Member was not paid and that
there was a St. George Dental Clinic, although the agreement to pay for Member’s dental work was off camera. It demonstrates
that Hart repeats the BENGAY Jingle to the extent that several views commented about the commercial and questioned if others
were paying attention to the embedded commercial. One view commented that it was done so cleverly that he almost couldn’t
tell that he was watching a commercial, another commented that she could memorize the jingle. It also demonstrates that Hart
advertises NIKE in each episode and that he was aware of how hot it was the day of production but had no provisions for those
needing a break from the heat.
Available from (if not attached): https://youtu.be/uN4Ou3Z5aMc

7
Other information PCC should consider:
Having extensive experience in Accounting, Management, Marketing, Financial Analysis and Pedagogy;
based on my professional expertise not only would it be imprudent, for UNION Leadership to maintain the
position of SAG-AFTRA Deputy General Counsel, Nicole Nakagawa, Et al.; that Kevin Hart, LOL president,
Jeff Clanagan and Lions Gate Television Inc, What The Fit Series I Episode 7 https://youtu.be/lK4eto4en2o , as
well as Episodes 3 https://youtu.be/EdRmaKHqYJY , 12 https://youtu.be/QR43TImr0dQ , and 15
https://youtu.be/T3fgGI-HjIw ; are anything less than Johnson & Johnson BENGAY ‘Skit’ Commercials, that
simultaneously promote other businesses including, but definitely not limited to NIKE; it would also be a
flagrant violation of the UNION’S fiduciary responsibilities to SAG-AFTRA Members. Leadership has a
vested obligation to stay abreast of precipitously evolving technologies that are considerably changing the
fabric of the entertainment industry, thus threatening to make actors superfluous and the UNION defunct. This,
mandates that leadership perpetually engage in perspicacious analyses of emerging trends and maintain
proficient preparedness to conduct sagacious and mutually beneficial negotiations that protect the incomes and
rights of ALL UNION Members. Be not deceived; Corporate Executives are fastidiously engaging in analyses
similar to the viewership ratio of .0002 to 1 as depicted on page 5 of this treatise. At a glance, in the minds of
business professionals, these comparisons are so miniscule they are not worth calculating, except to “LAUGH
OUT LOUD” at SAG-AFTRA Members and validate the development of more future cost effective lucrative
‘skit’ marketing videos that maximize profits from various emerging streams of revenue, at the expense of
bankrupting entertainment professionals.
What is most interesting to these businessmen are the ratios that complaining member is not privy to, i.e.,
the mega savings in fair payments, [residuals], health care, and pension benefits otherwise due to actors, as well
as appropriate payments to fans who, according to Arlene Lopez, gladly “worked for free LOL” (See
Attachment 2-2 Col. 2). It is obvious that companies like Allstate, for sake of example, are aware of the need
to change their Cyber-verse viewership. Ascertaining from Allstate’s 2018 adoption of more comedic skit
YouTube commercials, which generated more views than their original YouTube videos, but not one iota
impressive as the Pyramid Cyber-verse viewership that is being amassed by Kevin Hart, Jeff Clanagan and Jon
Feltheimer. SAG-AFTRA should ask what IF Allstate gained interest in joining ranks with Lionsgate and
Kevin Hart’s already established, seeking to develop relationships with more “organic” corporations? How
might this affect the income of their Mayhem Man, Dean Winters ( https://youtu.be/gucpp2X5lwo ) and their
iconic ‘Golden Voice’ Actor, Dennis Haysbert, (who they sometimes team up
( https://youtu.be/3gT1m8tKlL4)?”

What the UNION should also carefully consider, is the future of children in the entertainment industry, as
Hart’s specifically states, “I want to break new talent.” In their What the Fit Series 1 Episode 15, they use the
“kids, babies” in the kind of advertising skit that Queen Searles, UNION Member and Complainant herein,
used in the 90’s to attract students to her Honors Business & Finance Program and literally prevented cuts to
the Business Department. If Hart and his cohorts exploited babies to promote Johnson & Johnson’s BENGAY,
as they did Member herein, without providing them with appropriate payment and commercial contracts, and
successfully avoided UNION scrutiny and/or consequences; this is deplorable and could MARK the beginning
of the end of the “middle-man,” the SAG-AFTRA UNION.

8
Q. Searles

P. O. Box 6935

99