Quick Summary
Wig designer Terrence Davidson sued Nicki Minaj (whose real name is Onika Maraj) and her company Pink Personality, LLC, in February 2014.
The complaint alleges that Minaj stole Davidson's wig designs to sell and make from on her own behalf.
The lawsuit includes pictures of numerous wigs and alleges claims for breach of contract, interference with prospective business opportunities, conversion and misappropriation of property, unjust enrichment, and injunctive relief.
A PDF copy of the lawsuit is below.
Nicki Minaj Wig Complaint
Pictures of Nicki Minaj Wigs
Oddly, the lawsuit shows pictures of 6 wigs that Terrence Davidson supposedly owns, but only pictures of 5 wigs that Minaj allegedly stole.
What we think happened is the complaint mixed up the half-blonde half-pink wig and the superbass wig, and then forgot to include the half-blonde half-pink wig as being stolen.
Who knows. The attorney who drafted the complaint, Christopher Chestnut, apparently cannot spell, using "thier" instead of "their" (see paragraph 47), so confusing the wigs would not be surprising. Or maybe his client Terrence Davidson is confused about the wigs he claims to have designed and own.
It looks to us like the complaint is calling the the Half Blonde-Half Pink wig the Superbass wig.
We show them here so perhaps you can make sense of it and help out Mr. Chestnut and his client.
Pictures in the complaint of wigs Davidson alleges he designed and owns:
Pink Upper Bun Wig
Fox Fur Wig
Pink High Top Wig
Superbass Wig
Half Blonde-Half Pink Wig
VS Wig
Pictures in the complaint of wigs being sold that Davidson alleges are his:
Pink Upper Bun Wig
Fox Fur Wig
Pink High Top Wig
Superbass Wig
VS Wig
As you can see, the half blonde half pink wig is not listed as being improperly sold.
Looking at the pictures, the Superbass wig is the one that is half blonde and half pink.
Common Questions
Question: Is Nicki Minaj liable if someone else sells a wig looking like hers? If you look at the Spirit Halloween link in the complaint the wig is a "rap star" wig and does not mention Nicki Minaj at all.
Answer: No, she is not liable if she had nothing to do with the sale. It could be Davidson needs to sue Spirit Halloween for ripping off his design. There are no allegations that Minaj is responsible for the wig being sold at the Spirit Halloween site.
Question: If Davidson made the wigs for Minaj to wear doesn't she own them?
Answer: No. The general rule is if you create you own it. If you are an employee then what you create belongs to your employer, but Davidson was not Nicki's employee.
Usually there is a written contract assigning rights to someone else.
Here there was none.
The complaint alleges there was an "implied contract" based on an "understanding" Minaj could only use the wigs for her personal appearances.
This is a very weak contract claim. A he-said she-said situation.
Davidson was getting paid to do something. One thing is clear from the complaint, and that it is anything but clear about who owns the rights to the wigs.
The fact Davidson has not alleged claims such as copyright or trademark - typical property rights claims made by owners - could be a red flag the claims are weak.
Question: Is this really a $30 million dollar lawsuit?
Answer: Not in Davidson's wildest dreams, despite what his attorney is telling the media.
Despite the allegations in the lawsuit, the pitch that Davidson essentially created Minaj due to his wigs, and gets a piece of her empire such as her fragrance line, reality show fees, and so on, seems very far-fetched. The evidence described in the complaint is thin.
It seems unlikely, and facts are vague in the complaint, that Minaj would have agreed to pay a wig maker part of the money she makes from selling perfume.
In a CNN story Davidson's attorney, Christopher Chestnut, is quoted as saying "This is about a brand that Terrence has built."
We are not sure what the "brand" is and none is specified in the complaint. Is it that Minaj wears different, wild wigs? Does this mean Nicki Minaj cannot wear anyone else's wigs? Nothing else has created Nicki Minaj's popularity?
Question: Why is Pink Personality, LLC, being sued?
Answer: This is apparently Nicki Minaj's company - but it highlights more problems for Davidson.
The complaint alleges things like "Defendants" breached a contract, but any contract is likely to only be with Nicki Minaj or her company. Not both.
This vague lumping of an individual with a separate business entity together is poor draftsmanship and in our opinion the hallmark of weak claims. When you cannot identify exactly who a contract is with, when it was made and the precise terms, it can be a problem.
It is likely Minaj and/or Pink Personality will challenge the legal sufficiency of the allegations.
Text Version of the Complaint
COMPLAINT
COMES NOW Plaintiff, TERRENCE DAVIDSON, by and through his
undersigned counsel, and hereby files this Complaint against the Defendants,
ONIKA MARAJ and PINK PERSONALITY, LLC, and alleges as follows:
PARTIES, JURISDICTION & VENUE
1.
Plaintiff Terrence Davidson ("Plaintiff" or "Davidson") is a resident of the
State of Georgia and resides in this judicial district.
2.
Upon information and belief, Defendant Onika Maraj ("Maraj") is a resident
of the State of California. At all times material hereto, Defendant Maraj, who is
known by her stage name "Nicki Minaj," transacted and continues to transact
business in Georgia and specifically in this judicial district. Defendant Maraj is
subject to personal jurisdiction of this Court under Georgia's Long Arm Statute
(O.C.G.A. § 9-10-91).
3.
Upon information and belief, Defendant Pink Personality, LLC ("Pink
Personality") is a Delaware limited liability company with its principal place of
business in Los Angeles, California. At all times material hereto, Defendant Pink
Personality transacted and continues to transact business in Georgia and
specifically in this judicial district. Defendant Pink Personality is subject to
personal jurisdiction of this Court under Georgia's Long Arm Statute (O.C.G.A. §
9-10-91).
4.
Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391 because
a substantial part of the events or omissions giving rise to the claims set forth
herein occurred in this judicial district.
5.
This Court has subject matter jurisdiction over this matter pursuant to 28
U.S.C. § 1332, as the parties are completely diverse in citizenship and the amount
in controversy exceeds $75,000.
FACTS
I. The Beginning of Mr. Davidson's Business Relationship with Maraj.
6.
In or around January 2010, Mr. Davidson entered into a business
relationship with Maraj to serve as her hair stylist. Specifically, over the course of
the next few years, Davidson designed a number of wigs, presented them to Maraj,
and Miraj would then choose her preferred wig design for a particular event.
7.
In the years following the commencement Mr. Davidson's business
relationship with Maraj, his wig designs aided greatly in developing the
appearance that "Nicki Minaj" is now widely known for. Indeed, Nicki Minaj is
arguably known just as well for her wigs as she is her music.
8.
The wig designs that Mr. Davidson presented to Maraj, were fresh, unique
and highly distinguishable.
II. Specific Wigs Created by Mr. Davidson That Were Worn by Miraj
at Certain High Profile Events.
9.
As set forth above, Mr. Davidson created countless fresh, hip and unique
wigs from which Maraj could choose a style depending on the event.
10.
For example, on or about September of 2010, Terrence Davidson created
several pink wigs for Maraj to wear in her performance on the MTV Network
VMA's preshow.
11.
Of these pink wigs designed by Mr. Davidson, Maraj chose a pink wig with
an upper bun (the "Pink Upper Bun Wig"):
(available at http://celebsalon.sheknows.com/long-hairstyles/nicki-minajs-neon-
pink-hairstyle-at-the-vmas/)
12.
On or about December of 2010, Mr. Davidson created several wigs for
Onika Maraj to wear in a performance for the New York Radio Station, Hot 97's
Christmas Concert on December 25, 2010.
13.
Of these wigs designed by Mr. Davidson, Maraj chose a wig with patterns
and colors of a fox fur (the "Fox Fur Wig"):
(Available at http://urbanislandz.com/2010/12/28/nicki-minaj-rocks-the-mic-in- leopard-print-on-christmas-day-photo/).
14.
In or around January of 2011, Mr. Davidson created several new pink wigs
for Onika Maraj to wear for press appearances in London.
15.
Of these wigs designed by Mr. Davidson, On or about January 2011, Maraj
chose a tall, high top inspired wig (the "Pink High Top Wig"):
(Available at http://foxync.com/1919541/fab-or-fug-nicki-minajs-cotton-candy-hi-
top-wig-photos)
16.
In or around April of 2011, Mr. Davidson created several wigs for Maraj to
wear for her music video for the song "SuperBass."
17.
Of these wigs designed by Mr. Davidson, Maraj chose a wig (the
"SuperBass Wig"):
(Available at http://nickiminajcostume.blogspot.com/2013/01/get-nicki-minajs-
most-sought-after-wigs.html)
18.
In or around September of 2011, Mr. Davidson created several wigs for
Maraj to wear to The Mercedes Benz Fashion Week in New York City.
19.
For this event, Maraj chose the half blonde - half pink wig designed by Mr.
Davidson (the "Half Blonde-Half Pink Wig."):
(http://www.peoplestylewatch.com/people/stylewatch/package/gallery/0,,2022204
1_20527304_21052338,00.html)
20.
On or about November of 2011, Mr. Davidson created several pink wigs for
Maraj to wear in a performance for a Victoria's Secret special aired on CBS
21.
Maraj chose the pink curls wig (the "VS Wig") designed by Mr. Davidson
for her performance:
(Available at http://urbanislandz.com/2011/11/30/nicki-minaj-performs-live-at-
victorias-secret-fashion-show-video/nicki-minaj-victorias-secret-2/)
III. Various Business Opportunities Arise for Mr. Davidson as a Result
of his Fresh and Unique Wig Designs.
22.
As "Nicki Minaj" and her associated wig hair styles became more popular,
by November 2011, Al Branch, the brand manager for Maraj, began discussing
various business ventures with Mr. Davidson for Maraj's brand-specific wigs that
were created by him.
23.
In or around November 2011, Mr. Davidson informed Al Branch that he had
a television contract on the table for a reality television show searching for the next
top celebrity hairstylist.
24.
Nevertheless, Al Branch told Mr. Davidson to "hold off" on the reality
television show so that Mr. Davidson and Maraj could appear on a reality show
together.
25.
On or around November 9, 2011, there was a conference call, which
included Al Branch, Aaliyah Taylor (Mr. Davidson's broker), and Joseph Barrett
(Davidson's manager), to discuss potential joint business ventures between Mr.
Davidson and Maraj, and specifically, the creation of a wig line from Mr.
Davidson's designs and a possible reality TV show featuring Mr. Davidson and
Maraj. During this call, the parties agreed that they would continue to pursue the
wig and reality TV show ventures.
26.
Thus, on or around November 10, 2011, Mr. Davidson, Al Branch, and
Joseph Barrett met with Universal Television Executives to discuss the hair reality
television show involving Mr. Davidson and Maraj.
27.
Following the meeting, the television executives requested certain "footage"
mentioned during their meeting and Davidson subsequently sent the "footage" to
them.
28.
Additionally, in regards to the wig venture, on or around November 21,
2011, Michael Bong of "Shake & Go" Hair Company emailed Joseph Barrett and
Al Branch a full business proposal for the proposed wig line, which included full
profit and loss and a budget overview for the joint wig venture between Davidson
and Maraj.
29.
On or about November 21, 2011, Barrett informed Mr. Davidson of the
proposed wig deal. Mr. Davidson then informed Maraj of the proposal and stated
that Branch should be contacting her soon about the venture.
IV. Maraj and her Agents Shun Mr. Davidson and Take Active Steps
Toward Hurting his Career.
30.
By the end of 2011, many promising business ventures were on the table for
Mr. Davidson and Maraj to pursue together. Nevertheless, beginning in 2012,
Maraj and her agents became mum about the business ventures and took active
steps to isolate Mr. Davidson and preclude him from the notoriety he deserved for
his wig designs.
31.
For example, in January 2012, Joseph Barrett's office emailed The New
York Times Newspaper after reading an article in the newspaper written about
Maraj's wigs.
32.
To Mr. Barrett and Mr. Davidson's surprise, on or about January 21, 2012,
the writer of the article informed Mr. Barrett that newspaper had reached-out to
interview Mr. Davidson, but Amanda Silverman, a representative from Maraj's
team, stated that Mr. Davidson declined to be interviewed.
33.
Mr. Davidson was not informed about this interview, however, and thus,
neither he nor his representatives declined the interview.
34.
Many months passed, and neither Maraj nor her team responded to Mr.
Davidson's requests regarding the wig and reality TV business ventures.
35.
Indeed, in or around September of 2012, Al Branch emailed Mr. Davidson
asking for his hair care expertise about a possible hair care business deal with the
company. Mr. Davidson asked Branch about their previous wig deal proposal, but
again, did not receive a response.
36.
Indeed, in or around September of 2012, Al Branch emailed Mr. Davidson
asking for his hair care expertise about a possible hair care business deal with the
company. Mr. Davidson asked Branch about their previous wig deal proposal, but
again, did not receive a response.
V. Maraj's Unlawful Use of Mr. Davidson's Wig Designs is Discovered.
37.
In January 2013, Mr. Davidson ceased working as Maraj's hair stylist.
38.
Yet, just as Mr. Davidson was attempting to move-on with his career, to his
surprise, later in 2013, he discovered that Maraj took a number of his popular wig
designs, without his consent, and used them to start her own wig line.
39.
Indeed, the following wig styles designed by Mr. Davidson are now being
sold on numerous retail websites, as well as Maraj's website,
www.mypinkfriday.com:
The Pink Upper Bun Wig
(Available at http://www.target.com/p/nicki-minaj-pink-bun-wig/-/A-
14715501?ref=tgt_adv_XSG10001&AFID=Google_PLA_df&LNM=%7C14 715501&CPNG=Seasonal&kpid=14715501&LID=PA&ci_src=17588969&ci
_sku=14715501&gclid=CN68-fGd2bwCFQ1o7AodZBgAe)
The Fox Fur Wig
(Available at http://www.halloweencostumes.com/nicki-minaj-leopard-look-
wig.html)
The Pink High Top Wig
(Available at http://nickiminaj.shop.bravadousa.com/Product.aspx?pc=
BGAMNM19)
The SuperBass Wig
(Available at http://www.spirithalloween.com/product/rap-star-wig/)
The VS Wig
40.
Thus, without Mr. Davidson's knowledge and consent, Maraj surreptitiously
cut Mr. Davidson out of their wig venture and misappropriated his wig designs to
pursue the wig venture on her own.
41.
Additionally, many of the aforementioned wigs designed by Mr. Davidson
were misappropriated and used by Maraj to design bottle tops for her fragrance
line.
42.
Indeed, the Davidson designed wig bottle tops are the focal point of Maraj's
fragrance line.
43.
Thus, without Mr. Davidson's knowledge and consent, Maraj surreptitiously
used Mr. Davidson's wig designs to further her fragrance venture.
COUNT I
TORTIOUS INTERFERENCE WITH
PROSPECTIVE BUSINESS RELATIONS
44.
Plaintiff realleges the allegations of Paragraphs 1 through 43 as if fully set
forth herein.
45.
Defendants knew the business affairs of Mr. Davidson, including the unique
nature and designing of the wigs, its sales prospects, and the television and wig
"deals".
46.
Defendants and their agents tortuously interfered with Mr. Davidson's
business relations by, among other things:
a. Inducing and assisting with the attempt to impede Mr.
Davidson from knowing about the selling of multiple wigs
designed Mr. Davidson on Maraj's website and other retailers.
b. Inducing, assisting, aiding and abetting with the interference of
the television contract for the reality television hair show and
Universal Studios.
c. Inducing, assisting, aiding and abetting with the interference of
a "wig deal" for a wig line with "Shake & Go Hair Company."
d. Inducing, assisting, aiding, and abetting to prevent the publicity
of Mr. Davidson and the designing of his wigs for Maraj.
e. Inducing, assisting, aiding, and abetting others unknown to
Plaintiff to tortuously interfere with Mr. Davidson's business
relations.
47.
Defendants are liable to Mr. Davidson for all damages flowing from their
and thier agents' tortious interference with business relations.
COUNT II
BREACH OF IMPLIED CONTRACT
48.
Plaintiff realleges the allegations of Paragraphs 1 through 47 as if fully set
forth herein.
49.
Defendants knew the business affairs of Mr. Davidson, including the unique
nature and designing of the wigs, its sale prospects, popularity, and television and
wig "deals."
50.
Defendants understood and agreed that Maraj could only use Plaintiff's wig
designs solely for Maraj's personal use and attire for her appearances at various
entertainment and publicity events, consistent with her use of Plaintiff's wigs since
2010.
51.
The creation and design of the wigs was solely for Defendant Maraj's
personal use, rather than profit or self-dealing by Defendants. The parties never
discussed or contemplated that Defendant would engage in unfair and deceptive
business practices and unilaterally misappropriate or convert Plaintiff's wig
designs for Defendants' sole commercial purpose.
52.
Despite this mutual understanding and agreement under which the parties
operated since 2010, which included a confidentiality agreement, Defendants
breached the parties' implied contract, wrongfully misappropriated Plaintiff's wig
designs and wigs and entered into contracts with third parties for the sole
commercial purpose of profit and self-dealing.
53.
As a proximate cause of Defendants' actions, Plaintiff has suffered damages
in excess of $1,000,000.00.
COUNT III
UNJUST ENRICHMENT (QUANTUM MERUIT)
54.
Plaintiff realleges the allegations of Paragraphs 1 through 53 as if fully set
forth herein.
55.
From 2010 until 2013, Mr. Davidson performed services valuable to
Defendant Maraj by creating countless, fresh, hip, and unique wigs solely for her
celebrity appearances throughout the world, which Defendant Maraj knowingly
accepted. Mr. Davidson's unique wig designs significantly contributed to
Defendant Maraj's unsurpassed notoriety for her wigs.
56.
In November 2011, Mr. Davidson and Defendant Maraj discussed forming a
joint wig venture utilizing Mr. Davidson's unique wig designs, including the
creation of a new wig line and reality TV business ventures. Naturally, Defendant
expected compensation from the fruits of these business ventures.
57.
However, Defendants unilaterally misappropriated Mr. Davidson's wig
designs and pursued the wig venture on their own. Notably, Defendants have sold
Mr. Davidson's wigs on numerous retail websites, in addition to Maraj's website,
www.mypinkfriday.com, without the knowledge and consent of Mr. Davidson.
58.
Defendants also unilaterally misappropriated Mr. Davidson's wig designs
and used them to pursue a fragrance venture.
59.
As a proximate cause of these tortious acts, Defendants have been unjustly
enriched by selling Mr. Davidson's wigs in the public marketplace as if they
belonged to Defendant Maraj and entering into agreements with third parties to
recreate Mr. Davidson's wigs and designs for the sole commercial purpose of
profit and self-dealing.
60.
Upon information and belief, Defendants have received profits in excess of
$1,000,000.000 as a proximate cause of these tortious acts.
61.
Mr. Davidson has not received any compensation for Defendant's tortious
and unlawful use of his wigs and wig designs, yet Defendants have unfairly
profited from same.
62.
Plaintiff therefore seeks compensatory damages for the reasonable value of
his services, interest, and reasonable attorney's fees, in an amount to be determined
by the enlightened conscience of a jury.
COUNT IV
CONVERSION AND WRONGFUL MISAPPROPRIATION
OF PERSONAL PROPERTY
63.
Plaintiff realleges the allegations of Paragraphs 1 through 62 as if fully set
forth herein.
64.
Title and right to possession of the wig designs referenced herein belongs to
Plaintiff.
65.
Defendants' possession and retention of Plaintiff's wig designs constitutes a
wrongful act of dominion insofar as Defendants have entered into oral and written
contracts with other entities to sell Plaintiff's wigs and use Plaintiff's wig designs
for the sole purpose of self-dealing and profit.
66.
Defendants have refused to cease and desist from engaging in any and all
commercial activity relating to the sale, purchase or otherwise unauthorized use of
Plaintiff's wigs and wig designs, including but not limited to, execution of
contracts between Defendants and third parties utilizing Plaintiff's wigs and wig
designs.
67.
Upon information and belief, the value of Plaintiff's wig designs exceeds
$10,000,000.00.
68.
Plaintiff has suffered damages in excess of $1,000,000.00 based on
Defendants' conversion of his wig designs, including but not limited to lost profits,
in an amount to be determined at trial.
COUNT V
VIOLATION OF THE GEORGIA FAIR BUSINESS PRACTICES ACT
69.
Plaintiff realleges the allegations of Paragraphs 1 through 68 as if fully set
forth herein.
70.
Defendants have engaged in unfair and deceptive practices by selling
Davidson's wigs and wig designs in the consumer marketplace on retail websites,
in addition to Maraj's own website, www.mypinkfriday.com without the
knowledge and consent of Davidson. The general consuming public and unwitting
third parties who enter into contracts with Defendants for the purchase of
Davidson's wigs and wig designs are essentially unaware of the fraudulent
misrepresentation that the wigs and wig designs belong to Defendant Maraj.
71.
Defendants' unlawful business practices have the tendency or capacity to
deceive and thus violate the Georgia Fair Business Practices Act (hereinafter
"GFPBA"), set forth at OCGA § 10-1-390, et seq.
72.
As a proximate cause of Defendants' GFPBA violations, Plaintiff has
suffered damages, in an amount to be determined at trial.
COUNT VI
INJUNCTIVE RELIEF
73.
Plaintiff realleges the allegations of Paragraphs 1 through 72 as if fully set
forth herein.
74.
The wig designed by Plaintiff for Maraj's VMA performance is now being
sold on many other retail websites, in addition to Maraj's website,
www.mypinkfriday.com without the knowledge and consent of Plaintiff.
75.
The wig designed by Plaintiff for Maraj's Christmas Concert performance in
December 2010 is now being sold on many other retail websites, in addition to
Maraj's website, www.mypinkfriday.com without the knowledge and consent of
Plaintiff.
76.
The wig designed by Plaintiff for Maraj's press conferences and appearances
in London in January 2011 is now being sold on many other retail websites, in
addition to Maraj's website, www.mypinkfriday.com without the knowledge and
consent of Plaintiff.
77.
The wig designed by Plaintiff for Maraj's SuperBass video in April 2011 is
now being sold on many other retail websites, in addition to Maraj's website,
www.mypinkfriday.com without the knowledge and consent of Plaintiff.
78.
The wig designed by Plaintiff for Maraj's performance for a Victoria's
Secret special November 2011 is now being sold on many other retail websites, in
addition to Maraj's website, www.mypinkfriday.com without the knowledge and
consent of Plaintiff.
79.
Additionally, numerous wig designs created by Plaintiff are being used by
Defendants in furtherance of Maraj's fragrance business.
80.
While Plaintiff has both title and the right to possess the wig designs created
solely for Maraj's personal use, based on the foregoing, Defendants have
unlawfully converted and misappropriated Plaintiff's wig designs.
81.
It is presently unknown what other activities Defendants have engaged in or
plan to engage in relating to the unlawful use, duplication, or recreation of
Davidson's wigs or wig designs for the purpose of commercial profit and self-
dealing.
82.
As a proximate cause of Defendants' tortious acts, past and future, Plaintiff
has been irreparably harmed and will continue to be irreparably harmed for which
there is no adequate remedy of law. Additionally, there is a substantial likelihood
that Plaintiff will prevail on the merits. Consequently, Plaintiff seeks temporary
and permanent injunctive relief to enjoin Defendants from engaging in the
following acts, directly or indirectly: executing any oral or written contracts with
third parties for the purchase, sale or use of Plaintiff's wigs or wig designs in
commercial activity; communicating with any person or entity regarding use of
Plaintiff's wigs or wig designs in commercial activity; or taking any action
inconsistent with Plaintiff's dominion of his wigs and wig designs, for which he
has sole title and right to possession.
COUNT VII
PUNITIVE DAMAGES
83.
Plaintiff realleges the allegations of Paragraphs1 though 82 as if fully set forth
herein.
84.
Defendant's actions set forth above were conducted willfully, maliciously,
fraudulently, and with wantonness, oppression, and an entire want of care which
would raise the presumption of indifference to the consequence and entitle Mr.
Davidson to punitive damages in an amount sufficient to punish and deter such
conduct in the future.
WHEREFORE, Plaintiff prays this Honorable Court grant the following:
A. That summons and process be issued and served upon the Defendants;
B. That Plaintiff have a trial by jury of all issues so triable;
C. That Plaintiff recovers all damages against the Defendants in such an
amount that a jury determines from the evidence he is entitled to recover
under Georgia law including, but not limited to:
1. General damages for Mr. Davidson in an amount based on the
Defendant's conduct, or such other damages as provided by law
and established at trial;
2. Damages for Mr. Davidson's economic loss;
3. Damages for the lost profits which would have inured to
Davidson had the contracts and "deals" been performed and not
interfered by Defendants;
4. Damages against all Defendants for the profits and values of the
wigs sold on her website and other retailers;
5. Treble damages pursuant to O.C.G.A. § 10-1-399;
6. Punitive damages against all Defendants in an amount to be
determined at trial;
7. Attorneys fees and costs associated with the bringing and
prosecuting of this action; and
8. For such other relief as this Court deems just and appropriate.
This ____ day of February, 2014.
THE CHESTNUT FIRM, LLC
By:
Andrae P. Reneau Andrae P. Reneau
Georgia Bar No. 147026
303 Peachtree Street, N.E., Suite 4150
Atlanta, Georgia 30309
Tel: (470) 428-2120
areneau@chestnutfirm.com
Christopher M. Chestnut Florida Bar No. 0022409
5080 Newberry Rd., Suite 2A
Gainesville, Florida 32607
Tel: (352) 377-4444
chris.chestnut@chestnutfirm.com
Pro Hac Vice Application to be submitted
Attorneys for Plaintiff
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