(Page 1 of 25)

l Joshua R. Furman (Bar No. 225461) PILED

j rf@furmanlawyers .com
2 JOSHUA R. FURMAN LAW CORPORATION
14724 Ventura Boulevard, Suite 509
3 Sherman Oaks, California 91403 FEB 26 2018
Telephone: (8181 646-4300 •pSxecuuve Officer/Clerk
4 Facsimile: (818) 646-4301 Sherri R.yjj
Deputy
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5 Attorney for Plaintiff,
Robert Christopher Chatham
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7

8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
FOR THE COUNTY OF LOS ANGELES
10
11
ROBERT CHRISTOPHER CHATHAM, Case No.: BC 6 9 6 0 0 6
12 an individual, .
COMPLAINT FOR:
13 Plaintiff,
1. LEGAL MALPRACTICE
14 v.
2. NEGLIGENT
15 SHEPPARD MULLIN RICHTER & MISREPRESENTATION
HAMPTON, LLP, a California limited
16 liability partnership; DEAN MATTHEW 3. FRAUD
RICHARDSON, an individual; DOES 1­
17 10, inclusive, 4. BREACH OF FIDUCIARY DUTY
18 Defendants. DEMAND FOR JURY TRIAL
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C: IT /CASE: BC696006
LEA/DEF#;. ■ . 1

RECEIPT #; CCH465980057
5 LDI/£.3 DATE PAID: 03/01/13 10:52 AM
PAVMENT: #435.00 310
RECEIVED:
CHECK: #435.00
CASH: #0.00
CHANGE: #0.00
CARD: #0.00

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1 Plaintiff ROBERT CHRISTOPHER CHATHAM alleges the following:

2 PARTIES
3 1. Plaintiff ROBERT CHRISTOPHER CHATHAM is an individual residing
4 in Los Angeles County.
5 2. On information and belief, Defendant SHEPPARD MULL1N RICHTER &
6 HAMPTON, LLP is a California limited liability partnership with a primary place of
7 business in Los Angeles County.
8 3. On information and belief, Defendant DEAN MATTHEW RICHARDSON
9 is an individual residing in Orange County. At all times relevant to this action, Richardson
10 was an attorney licensed to practice law in the State of California. Defendant Richardson
11 practices law as a partner with the law firm Sheppard Mullin.
12 JURISDICTION AND VENUE
13 4. Jurisdiction is proper in this Court as the amount in controversy exceeds
14 $25,000.00.
15 5. Venue is proper in this Court because the causes of action arose in Los
16 Angeles County and because at least one Defendant is resident therein.
17 FACTS COMMON TO ALL CAUSES OF ACTION
18 6. This case arises out of Richardson and Sheppard Mullin’s material support
19 of a Ponzi scheme perpetrated by their client, nonparty Mary Carole McDonnell.
20 7. In early 2013, Plaintiff Chatham, himself a lawyer, was contacted by
21 McDonnell, also a client of Chatham, who offered Chatham an investment opportunity to
22 take advantage of a “gifting program” that provided tax benefits to McDonnell and her
23 alleged family trusts, while providing a healthy return to Chatham.

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24 8. Chatham was reluctant to invest money to McDonnell without
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25 documentation of her assets, the nature of the trusts, and her ability to repay the
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27 9. In order to assuage Chatham’s concerns, McDonnell produced an opinion

28 letter dated February 15, 2013, and signed by Richardson on Sheppard Mullin letterhead.
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1 Richardson’s February 15, 2013 opinion letter is attached hereto as Exhibit A.

2 10. Richardson’s opinion letter was prepared for the purposes of providing
3 McDonnell documentation of her assets to persons interested in her investment proposals.
4 Richardson’s letter stated that Richardson had represented McDonnel “since the mid-
5 1990s” and that the value of McDonnell’s assets was “quite substantial” and “many
6 millions of dollars’ worth.” The letter was addressed to McDonnell herself but was clearly
7 intended as a “To Whom It May Concern” letter to validate McDonnell’s assets and
8 invited “anyone” with questions about McDonnell’s assets to contact Richardson.
9 11. In an email on or about September 10, 2014, Richardson and Chatham
10 discussed that McDonnell had a net worth of $80 million to $100 million.
11 12. In another opinion letter dated December 15, 2014, Richardson again stated
12 he had represented McDonnell since “the mid-1990s.” Richardson continued, “I am a
13 practicing tax attorney, rated AV Preeminent 5.0/5.0 by Martindale, with nearly 30 years
14 of experience.” Richardson then stated, “This letter is to confirm for you my
15 understanding that Ms. McDonnell is the beneficiary of an irrevocable trust established
16 by her parents many years ago what holds assets (primarily, real estate), the value of which
17 is well is excess of $400 million, of which Ms. McDonnell’s share exceeds $80 million.”
18 The letter further specified: “pursuant to the terms of the trust, she will be entitled to a
19 distribution of the trust assets over a period of two years, starting in June 2015, and that
20 the total amount of such distributions will be in excess of $80 million ... .” This letter
21 was likewise signed by Richardson and delivered on Sheppard Mullin letterhead.
22 Richardson’s December 15, 2014 opinion letter is attached hereto as Exhibit B.
23 13. The December 15, 2014 letter was also provided by McDonnell to Chatham
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L.J 24 in order to assuage him of concerns over McDonnell’s assets and ability to repay any
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h- ■? 25 investments in the trust “giving program.” While no addressee was included in the copy

<3 26 of the December 15, 2014 letter that Chatham received, the information about
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27 McDonnell’s assets was consistent with the other representations that Richardson had
28 made generally and specifically to Chatham.
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1 14. In connection with Richardson’s written verification of McDonnell’s assets,

2 Chatham took up Richardson’s invitation to contact him. Chatham communicated with
3 Richardson by telephone and via email. In these communications, Richardson repeatedly
4 confirmed to Chatham that he was McDonnell’s attorney.
5 15. On one phone call on May 28, 2014, Chatham asked Richardson if the letter
6 verifying McDonnell’s net worth was accurate. Chatham explained to Richardson that he
7 wanted to know if Richardson’s letter was accurate because Chatham was considering
8 whether to participate in another series of the investment programs with McDonnell. In
9 response, Richardson verified and ratified the representations in his letter, stating that his
10 letter was accurate concerning McDonnell’s assets.
16. Prior to and contemporaneously with the phone calls and letters with
12 Richardson, McDonnell also confirmed to Chatham that Richardson was her attorney.
13 17. Chatham relied upon Richardson’s statements because Richardson was
14 McDonnell’s attorney, Richardson had been McDonnell’s attorney for over 20 years,
15 Richardson was a highly experienced attorney in the areas of tax and “complex financing,”
16 Richardson worked for Sheppard Mullin—a large and respected law firm, and because
17 Richardson told Chatham that the letter he had written confirming McDonnell’s assets
18 was accurate.
19 18. In reliance on the verifications that he had received concerning
20 McDonnell’s assets, Chatham entered into another series of the investment programs with
21 McDonnell between July 2013 and August 2014. These were each secured by promissory
22 notes obligating McDonnell and repaid under their respective terms.
23 19. In 2014, McDonnell began suggesting more frequent and more substantial

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24 participations from Chatham. Chatham was hesitant to consider making these investments
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h* 4 25 considering the financial risk involved, but was assuaged by his May 28, 2014 telephone
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27 of dollars.”
28 20. In reliance on Richardson’s multiple representations, Chatham agreed
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1 invest more money with McDonnell. Chatham would not have participated in
2 McDonnell’s proposed investments if Richardson had not confirmed to him that
3 McDonnell had the assets to make good on the investment repayment terms.
4 21. From April 3, 2015, to May 19, 2016, Chatham entered into another series
5 of investments with McDonnell. The investments were again secured by promissory notes
6 attaching McDonnell’s assets and the assets of two trusts, which included McDonnell’s
7 home—at the time worth several million more than the liabilities under the notes.
8 22. By July 2016, McDonnell had defaulted on the outstanding notes in the
9 amount of $ 1.899,260.60.
10 23. In order to resolve the default, Chatham entered into a subsequent
11 agreement with McDonnell, which affirmed the outstanding investment obligations per
12 the notes, established new repayment terms for the debts, and set a payment schedule.
13 This agreement was executed on July 25, 2016.
14 24. In entering into the July 25,2016 agreement, Chatham relied on the multiple
15 representations made by Richardson concerning McDonnell’s assets. Chatham would
16 never have consented to yet another agreement with McDonnell if he was not convinced,
17 based on the information that Richardson had provided and the solid reputation of
18 Richardson and Sheppard Mullin, that he had been provided with an accurate portrayal of
19 McDonnell’s assets.
20 25. By February 2017, McDonnell had breached the July 25, 2016 agreement
21 and Chatham filed a demand for arbitration against McDonnell pursuant to the agreement.
22 26. Chatham prevailed in the arbitration, and a judgment confirming the
23 arbitration award was issued by the Los Angeles County Superior Court in the amount of
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24 $3,400,282.20 on September 20, 2017.
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25 27. Throughout the arbitration and in the petition to confirm the arbitration
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27 28. The value of the judgment in Chatham’s favor as of today, including accrued
28 late fees, interest, and attorneys’ fees, exceeds $4,300,000.
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1 29. McDonnell has not paid any money towards the judgment.
2 30. In post-judgment enforcement efforts and investigation after September 20,
3 2017, Chatham has determined that McDonnell does not have, and apparently never had,
4 $80 million or more in assets. In fact, McDonnell appears to be insolvent. Even
5 McDonnell’s home securing the notes has now been foreclosed on.
6 31. Further post-judgment investigation, including an interview with
7 McDonnell’s nephew in the process of securing his third-party debtor examination.
8 McDonnell’s nephew explained that his family did not have a $400 million trust, or any
9 kind of wealth approaching that amount, and that he did not understand why anyone would
10 make such false representations to Chatham.
11 32. In light of the foregoing, Richardson and Sheppard Mullin’s representations
12 to Chatham that McDonnell had assets of over $80 million was false.
13 33. Richardson and Sheppard Mullin’s representations were false despite the
14 fact that Richardson was fully versed in McDonnell’s “gifting program” investment
15 system and had even recommended that others participate in McDonnell’s programs. At
16 least one of the other participants in McDonnell’s scheme was Richardson’s own personal
17 trainer, who invested with McDonnell at Richardson’s recommendation and lost his life
18 savings.
19 34. The falsity of Richardson and Sheppard Mullin’s representations has now
20 been confirmed again and again by arbitration and judicial decisions. In granting an award
21 in favor of Chatham and against McDonnell, the arbitrator characterized McDonnell’s
22 “gifting program” as nothing more than a Ponzi scheme perpetrated by McDonnell and
23 her “agents”: “McDonnell represented the program less as a ‘gifting’ program and more
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24 as an investment opportunity. She and/or her agents drafted the promissory notes as the
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1-4 25 vehicle for the investment. The facts surrounding this ‘gifting program ’ suggest that
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26 this was more like a Ponzi scheme than a legitimate investment program ... .”
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27 (Emphasis added.)
28 35. Confirming the arbitration award and issuing judgment, the Superior Court
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1 Judge was less equivocal about the nature of the fraud. In an extraordinarily cautious and
2 thorough opinion, the Judge conducted a de novo analysis of several issues in the
3 arbitration—even though no such analysis was necessary. After reviewing the evidence
4 in support of the arbitrator’s decision, the Judge found he had no choice but to confirm:
5 The communications of the parties and the representations made by
6 the parties make it relatively clear that Petitioner was investing in, and
7 expected a very significant return on, his investment in whatever
8 activities the McDonnell Family Trust was involved in. Even at this
9 stage of the proceedings Respondent fails to make it clear what
10 Respondent was doing in the form of business activity with these
11 funds which generated profits or returns sufficient to pay any return
12 on investment. The court is left with the conclusion that Respondent
13 cannot offer such evidence as it would support the arbitrator’s
14 conclusion that this was nothing more than a Ponzi scheme.
15 (Tentative Ruling adopted as Final September 20, 2017, Chatham v. McDonnell, et al.,
16 Los Angeles County Superior Court Case No. BS 170675.)
17 36. The evidence that the Superior Court Judge was looking for is the exact
18 same evidence that Richardson and Sheppard Mullin should have had when Richardson’s
19 opinion letters confirming McDonnell’s assets and ability to repay investments were
20 written. If that evidence did not exist at the time the Judge issued his opinion in 2017, it
21 did not exist when Richardson wrote the opinion letters in 2013 and 2014. Accordingly,
22 there was no excuse for Richardson and Sheppard Mullin’s false statements.
23 FIRST CAUSE OF ACTION
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24 (Legal Malpractice - Against Richardson, Sheppard Mullin, and Does 1-5)
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Y-* 25 37. Plaintiff incorporates by reference paragraphs 1 through 36 of this
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28 beneficiary of Defendants’ services in confirming the value of McDonnell’s assets.
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Complaint
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1 Defendants therefore owed a duty to Plaintiff to exercise reasonable care and professional
2 prudence in conformity with the standard of care for similarly situated attorneys as well
3 as a general duty to take reasonable steps to avoid reasonably foreseeable risks in
4 undertaking the legal services described herein.
5 39. Defendants breached their duties to Plaintiff by failing to act in conformance
6 with the applicable standard of care as set forth above.
7 40. As a direct result of the negligent acts and omissions by Defendants stated
8 herein, and other such acts as may be discovered in the future, Plaintiff has suffered and
9 continue to suffer substantial losses in the form of the loss of the value of his contributions
10 to McDonnell’s investment programs, including the value of the July 25, 2016 agreement,
11 attorneys’ fees and costs incurred in enforcement against McDonnell, and other damages,
12 the precise amount of damages for which will be proven at trial.
13 SECOND CAUSE OF ACTION
14 (For Negligent Misrepresentation - Against Richardson, Sheppard Mullin, and
15 Does 1-10)
16 41. Plaintiff incorporates by reference paragraphs 1 through 40 of this
17 Complaint as though set forth herein in their entirety.
18 42. Defendants made affirmative representations to Plaintiff concerning
19 McDonnell’s assets.
20 43. The representations made by Defendants were material such that Plaintiff
21 would not have invested with McDonnell or entered into the July 25, 2016 agreement with
22 McDonnell if Defendants had not made such representations.
23 44. Defendants had no reasonable ground for asserting that the representations
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24 made to Plaintiff concerning McDonnell’s assets were true at the time they were made,
25 because McDonnell did not have Over $80 million at the time, McDonnell was not going
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(3 26 to receive distributions of over $80 million within two years, and Defendants made the
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27 representations that McDonnell had such assets without performing any adequate
28 investigation to confirm the truth or falsity of those matters.
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1 45. Defendants intended to induce Plaintiff’s reliance on their representations

2 concerning McDonnell’s assets because they knew Plaintiff was considering whether to
3 participate in McDonnell’s investment programs and they knew they needed to tell
4 Plaintiff that McDonnell had substantial assets in order to convince Plaintiff to participate.
5 46. Plaintiff justifiably relied on Defendants’ representations because
6 Defendants held themselves out as McDonnell’s attorney of over 20 years, because
7 Defendants affirmed to Plaintiff that their misrepresentations were accurate, and because
8 Defendants were a highly qualified attorney and a very large, reputable law firm.
9 47. As a direct result of the negligent misrepresentations by Defendants stated
10 herein, Plaintiff has suffered and continues to suffer substantial losses in the form of the
11 loss of the value of his contributions to McDonnell’s investment programs, including the
12 value of the July 25, 2016 agreement, attorneys’ fees and costs incurred in enforcement
13 against McDonnell, and other damages, the precise amount of damages for which will be
14 proven at trial.
15 THIRD CAUSE OF ACTION
16 (Fraud - Against Richardson)
17 48. Plaintiff incorporates by reference paragraphs 1 through 47 of this
18 Complaint as though set forth herein in their entirety.
19 49. Richardson made affirmative representations to Plaintiff concerning
20 McDonnell’s assets.
21 50. The representations made by Richardson were material such that Plaintiff
22 would not have participated in McDonnell's programs or entered into the July 25, 2016
23 agreement with McDonnell if Richardson had not made such representations.
e.v' 24 51. Richardson knew that the representations he made to Plaintiff concerning
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25 McDonnell’s assets were false at the time he made them, because McDonnell did not have
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27 going to inherit $80 million imminently. Richardson was also fully versed with
28 McDonnell’s scheme, having recommended participation to other persons.
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1 52. Richardson intended to induce Plaintiffs reliance on his misrepresentations

2 concerning McDonnell’s assets because he knew Plaintiff was considering whether to
3 participate in McDonnell’s investment programs and he knew he needed to tell Plaintiff
4 that McDonnell had substantial assets in order to convince Plaintiff to participate.
5 Richardson’s intent in so doing was to make sure that McDonnell obtained money from
6 Chatham, regardless of the risk posed to Chatham by McDonnell’s failure to repay, and
7 regardless of the illegitimate nature of McDonnell’s Ponzi scheme. In this, Richardson
8 favored McDonnell to the derogation of his duties to Chatham.
9 53. Plaintiff justifiably relied on Richardson’s misrepresentations because
10 Richardson held himself out as McDonnell’s attorney of over 20 years, because
11 Richardson affirmed to Plaintiff that his misrepresentations were accurate, and because
12 Richardson was a highly qualified attorney working for a very large, reputable law firm.
13 54. As a direct result of the misrepresentations by Richardson, Plaintiff has
14 suffered and continues to suffer substantial, losses in the form of the loss of the value of
15 the promissory notes to McDonnell, including the value of the July 25, 2016 agreement,
16 attorneys’ fees and costs incurred in enforcement against McDonnell, and other damages,
17 the precise amount of damages for which will be proven at trial.
18 55. The conduct of Defendants was willful, wanton, malicious, and despicable
19 and subjected Plaintiff to cruel and unjust hardship in conscious disregard of his rights.
20 Defendants’ conduct was such that Plaintiff is entitled to exemplary damages to punish
21 Defendants and deter future harms like those suffered by Plaintiff.
22 FOURTH CAUSE OF ACTION
23 (Breach of Fiduciary Duty - Against Richardson, Sheppard Mullin, and Does 1-10)
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24 56. Plaintiff incorporates by reference paragraphs 1 through 55 of this
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■ cs 26 57. Defendants owed certain fiduciary duties to Plaintiff in the course and scope
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27 of providing legal services to Plaintiff. Such duties including, but are not limited to, a
28 duty to act at all times in good faith and in Plaintiffs best interests; a duty to, among other
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Complaint

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1 things, perform the services for which they were retained with reasonable care and skill;
2 a duty to act in Plaintiffs highest and best interests at all times; and a duty to not expose
3 Plaintiff to any unnecessary risk or peril. This fiduciary and confidential relationship was
4 never repudiated by Defendants at any time relevant hereto.
5 58. Defendants breached their fiduciary duties to Plaintiff by putting
6 Defendants’ own, and each of their own, interests and/or the interests of McDonnell,
7 ahead of Plaintiff s interests.
8 59. For example, Defendants breached their fiduciary duties to Plaintiff by
9 falsely assuring him about the amount and status of McDonnell’s assets. Defendants
10 further breached their fiduciary duties to Plaintiff by elevating the interests of McDonnell
11 in receiving money from Plaintiff above the interests of Chatham in being repaid that
12 money. In so doing, Defendants conspired with McDonnell to engage in fraud for the
13 purposes of taking money from Chatham based on the false pretense that McDonnell had
14 sufficient assets to repay the money, and that McDonnell’s investment program was
15 legitimate.
16 60. As a direct result of the breaches of fiduciary duty by Defendants, Plaintiff
17 has suffered and continues to suffer substantial losses in the form of the loss of the value
18 of his contributions to McDonnell’s investment programs, including the value of the July
19 25, 2016 agreement, attorneys’ fees and costs incurred in enforcement against McDonnell,
20 and other damages, the precise amount of damages for which will be proven at trial.
21 61. The conduct of Defendants was willful, wanton, malicious, and despicable
22 and subjected Plaintiff to cruel and unjust hardship in conscious disregard of his rights.
23 Defendants’ conduct was such that Plaintiff is entitled to exemplary damages to punish
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24 Defendants and deter future harms like those suffered by Plaintiff.
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Complaint

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1 PRAYER FOR RELIEF

2 WHEREFORE,. Plaintiff respectfully request judgment against Defendants as
3 follows:
4 1. For actual damages according to proof at trial but in no event less than
5 $4,300,000;

6 2. For other, special and consequential damages in an amount to be proven at

7 trial;
8 3. For punitive damages in an amount sufficient to deter similar future
9 conduct;
10 4. For prejudgment interest from the date(s) of injury;
11 5. For costs of suit;
12 6. For such other and further relief as the Court deems just, equitable, and
13 proper.
14
Dated: Februaiy 26, 2018 JOSHUA R. FURMAN LAW CORP.
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18 By:
Joshua R. Furman
19 Attorney for Plaintiff
ROBERT CHRISTOPHER CHATHAM
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1 DEMAND FOR JURY TRIAL

2 Plaintiff ROBERT CHRISTOPHER CHATHAM hereby demands a trial by jury
3 for all claims upon which jury trial is proper.
4
Dated: February 26, 201 8 JOSHUA R. FURMAN LAW CORP.
5

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By:
8 Joshua R. Furman
Attorney for Plaintiff
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ROBERT CHRISTOPHER CHATHAM
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Complaint

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CM-010
ATTORNEY OR PARTY WITHOUT ATTORNEY /Name. Sfafo Bar number, and address): FOR COURT USB ONLY
~ Joshua R. Furman, Bar No. 225461
JOSHUA R. FURMAN LAW CORP.
14724 Ventura Blvd., Suite 509
. Sherman Oaks, CA 91403 Sui
TELEPHONE NO.: (818) 646*4300 fax no.: (818) 646-4301
attorney for (Name): Robert Christopher Chatham
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
street address: 111 N. Hill Street
FEB 2 6 2018
MAILING ADDRESS:
Si lem h.
^gcutive Officer/Clerk
cityand zip code: Los Angeles 90012 Bf.
branch name: Stanley Mosk Courthouse si Deputy
iden
CASE NAME:
Robert Christopher Chatham v. Sheppard Mullin, et al.
CASE NUMBER:
CIVIL CASE COVER SHEET Complex Case Designation
I / I Unlimited
(Amount
I I Limited
(Amount I I Counter 1 I Joinder RP. « 9 6 0 0 fi
JUDGE:
demanded demanded is Filed with first appearance by defendant
exceeds $25,000) $25,000 or less) _______ (Cal. Rules of Court, rule 3.402) DEPT:

Items 1-6 below must be completed (see instructions on page 2).

1. Check one box below for the case type that best describes this case:
Auto Tort Contract Provisionally Complex Civil Litigation
□ Auto (22) I I Breach of contract/warranty (06) (Cal. Rules of Court, rules 3.400-3.403)
I I Uninsured motorist (46) I I Rule 3.740 collections (09) I I Antitmst/Trade regulation (03)
Other PI/PD/WD (Personal Injury/Property I I Other collections (09) I I Construction defect (10)
Damage/Wrongful Death) Tort
I I Asbestos (04)
□
____ Insurance coverage (18) I I Mass tort (40)
I I Other contract (37) I I Securities litigation (28)
□ Product liability (24) Real Property I I Environmental/Toxic tort (30)
I I Medical malpractice (45) I I Eminent domain/inverse I I Insurance coverage claims arising from the
□ Other PI/PD/WD (23) ___ condemnation (14) above listed provisionally complex case
I I Wrongful eviction (33) types (41)
Non-PI/PD/WD (Other) Tort
Enforcement of Judgment
I----- 1 Business tort/unfair business practice (07) I I Other real property (26)
□ Civil rights (08) Unlawful Detainer 1 I Enforcement of judgment (20)
Lj Defamation (13) I I Commercial (31) Miscellaneous Civil Complaint
□ Fraud (16) □ Residential (32) □ RICO (27)
LJ Intellectual property (19) I I Drugs (38) I I Other complaint (not specified above) (42)
I / 1 Professional negligence (25) Judicial Review Miscellaneous Civil Petition
□ Other non-PI/PD/WD tort (35) I I Asset forfeiture (05) ___
I I Partnership and corporate governance (21)
Employment I I Petition re: arbitration award (11) | |
____ Other petition (not specified above) (43)
Wrongful termination (36) I I Writ of mandate (02)
I 1 Other employment (15) I I Other judicial review (39)
2. This case I I is I ✓ I is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
factors requiring exceptional judicial management: ___
a. I I Large number of separately represented parties d. I I Large number of witnesses
b. I I Extensive motion practice raising difficult or novel e. I I Coordination with related actions pending in one or more courts
___ issues that will be time-consuming to resolve ___ in other counties, states, or countries, or in a federal court
c. 1 I Substantial amount of documentary evidence f. I I Substantial postjudgment judicial supervision

3. Remedies sought (check all that apply): a.I ✓ I monetary b.l I nonmonetary: declaratory or injunctive relief c. I ✓ Ipunitive
4. Number of causes of action (specify): Four; Legal malpractice, negligent misrep., fraud, breach fiduciary duty
J5jj This case I I is 1 / I is not a class action suit. ___
6, If there are any known related cases, file and serve a notice of related case. (Youpriy useVorm CM-015.)
Cli
rOate: February 26, 2018
Joshua R. Furman
(TYPE OR PRINT NAME)
► (SIGNATURE OF PARTY OR ATTORNEY FOR PARTY)
1 NOTICE 77
cp Plaintiff must file this cover sheet with the first paper filed in the action or proceeding "(except small claims cases or cases filed
under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
in sanctions.
• File this cover sheet in addition to any cover sheet required by local court rule.
• If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
other parties to the action or 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.
Form Adopted for Mandatory Use Cal. Rules of Court, tulos 2.30.3.220. 3.400-3.403. 3.740:
Judicial Council of California CIVIL CASE COVER SHEET Cal. Standards of Judicial Administration, std. 3.10
CM-OIQ (Rev. July 1, 2007] www.courtinfo.GG.gQv

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SHORT TITLE;
Robert Christopher Chatham v. Sheppard Mullin, et al.
CASE NUMBE
BC fi 9 6 0 0 6
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 2.3 in all new civil case filings in the Los Angeles Superior Court.

Step 1: After completing the Civil Case Cover Sheet (Judicial Council form CM-010), find the exact case type in
Column A that corresponds to the case type indicated in the Civil Case Cover Sheet.

Step 2: In Column B, check the box for the type of action that best describes the nature of the case.

Step 3: In Column C, circle the number which explains the reason for the court filing location you have
chosen.

Applicable Reasons for Choosing Court Filing Location (Column C)

1. Class actions must be filed in the Stanley Mosk Courthouse, Central District. 7. Location where petitioner resides.
2. Permissive filing in central district. 8. Location wherein defendant/respondent functions wholly.
3. Location where cause of action arose. 9. Location where one or more of the parties reside.
4. Mandatory personal injury filing in North District. . 10. Location of Labor Commissioner Office.
11. Mandatory filing location (Hub Cases - unlawful detainer, limited
5. Location where performance required or defendant resides.
non-collection, limited collection, or personal injury).
6. Location of property or permanently garaged vehicle.

A B C
Civil Case Cover Sheet Type of Acb'on Applicable Reasons -
Category No. (Check only one) See Step 3 Above

Auto (22) □ A7100 Motor Vehicle - Personal Injury/Property Damage/Wrongful Death 1,4,11
£ t
Uninsured Motorist (46) □ A7110 Personal Injury/Property Damage/Wrongful Death - Uninsured Motorist 1,4,11

□ A6070 Asbestos Property Damage 1,11

Asbestos (04)
□ A7221 Asbestos - Personal Injury/Wrongful Death 1.11
£r
Product Liability (24) □ A7260 Product Liability (not asbestos or toxic/environmental) 1,4,11
I
—^ 3
<u
£« <=> □ A7210 Medical Malpractice - Physicians & Surgeons 1,4, 11
.2, 3 Medical Malpractice (45)
□ A7240 Other Professional Health Care Malpractice 1,4, 11
c
e
□ A7250 Premises Liability (e.g., slip and fall)
:si | Other Personal
□ A7230 Intentional Bodily Injury/Property Damage/Wrongful Death (e.g.,
1.4.11
£ Injury Property 1.4.11
assault, vandalism, etc.)
cf a
m\~yr
Damage Wrongful
Death (23) □ A7270 Intentional Infliction of Emotional Distress
1,4, 11

□ A7220 Other Personal Injury/Property Damage/Wrongful Death

1.4.11

LACIV 109 (Rev 2/16) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3
LASC Approved 03-04 AND STATEMENT OF LOCATION Page 1 of 4

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(Page 23 of 25)

'■n

SHORT TITLE: CASE NUMBER

Robert Christopher Chatham v. Sheppard Mullin, et al.

A B C Applicable
Civil Case Cover Sheet Type of Action Reasons - See Step 3
Category No. (Check only one) Above

Business Tort (07) □ A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1,2,3
tr
l£ Civil Rights (08) □ A6005 Civil Rights/Discrimination 1,2,3

ls Q
Defamation (13) □ A6010 Defamation (slander/libel) 1,2,3
■&
=> 3
C Fraud (16) □ A6013 Fraud (no contract) 1,2,3

!i Professional Negligence (25)

□ A6017 Legal Malpractice 1©3

ft
o m
Z Q
□ A6050 Other Professional Malpractice (not medical or legal) 1,2,3

Other (35) □ . A6025 Other Non-Personal Injury/Property Damage tort 1,2,3

Wrongful Termination (36) □ A6037 Wrongful Termination 1,2,3

a>
E
>> □ A6024 Other Employment Complaint Case 1,2,3
Q. Other Employment (15)
E □ A6109 Labor Commissioner Appeals 10
Ui

□ A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful

2,5
eviction)
Breach of Contract/ Warranty 2,5
(06) □ A6008 Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence)
(net insurance) 1.2, 5
□ A6019 Negligent Breach of Contract/Warranty (no fraud)
1,2,5
□ A6028 Other Breach of Contract/Warranty (not fraud or negligence)

□ A6002 Collections Case-Seller Plaintiff 5, 6,11

£ Collections (09)
§ □ A6012 Other Promissory Note/Collections Case 5,11
o
□ A6034 Collections Case-Purchased Debt (Charged Off Consumer Debt 5. 6,11
___________ Purchased on or after January 1,2014)_____________________

Insurance Coverage (18) □ A6015 Insurance Coverage (not complex) 1,2, 5,8

□ A6009 Contractual Fraud 1.2, 3,5

Other Contract (37) □ A6031 Tortious Interference 1.2, 3,5
□ A6027 Other Contract Dispute(not breach/insurance/fraud/negligence) 1.2, 3, 8,9

Eminent Domain/Inverse
Condemnation (14)
□ A7300 Eminent Domain/Condemnation Number of parcels. 2,6
£
cu Wrongful Eviction (33) □ A6023 Wrongful Eviction Case 2,6
o
0.
re □ A6018 Mortgage Foreclosure 2,6
Other Real Property (26) □ A6032 Quiet Title 2,6
□ A6060 Other Real Property (not eminent domain, landlord/tenant, foreclosure) 2,6
C3
h- -k
Unlawful Detainer-Commercial
□ A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 6.11
(31)
Unlawful Detainer-Residential
■r--? % □ A6020 Unlawful Detainer-Residential (not drags or wrongful eviction) 6,11
(32)
a o
Unlawful Detainer-
I □ A6020F Unlawful Detainer-Post-Foreclosure 2, 6,11
Post-Foreclosure (34)
«c
3 Unlawful Detainer-Drags (38) □ A6022 Unlawful Detainer-Drags 2, 6, 11

LACIV 109 (Rev 2/16) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3
LASC Approved 03-04 AND STATEMENT OF LOCATION Page 2 of 4

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(Page 24 of 25)

>v

SHORT TITLE: CASE NUMBER

Robert Christopher Chatham v. Sheppard Mullin, et al.

A B C Applicable
Civil Case Cover Sheet Type of Action Reasons • See Step 3
Category No. (Check only one) Above

Asset Forfeiture (05) □ A6108 Asset Forfeiture Case 2, 3,6

i Petition re Arbitration (11) □ A6115 Petition to Compel/Confirm/Vacate Arbitration 2,5

>
£ □ A6151 Writ - Administrative Mandamus 2,8
Writ of Mandate (02) □ A6152 Writ - Mandamus on Limited Court Case Matter 2
■o
□ A6153 Writ - Other Limited Court Case Review 2
”5

Other Judicial Review (39) □ A6150 Other Writ/Judicial Review 2,8

Antitrust/Trade Regulation (03) □ A6003 Antitrust/Trade Regulation 1.2,8

c
*o> Construction Defect (10) □ A6007 Construction Defect 1,2,3

so. Claims Involving Mass Tort

(40)
□ A6006 Claims Involving Mass Tort 1,2,8

E
o
o Securities Litigation (28) □ A6035 Securities Litigation Case 1,2,8

Toxic Tort
□ A6036 Toxic Tort/Environmental 1,2, 3,8
.2 Environmental (30)
.<2
o Insurance Coverage Claims
£ □ A6014 Insurance Coverage/Subrogation (complex case only) 1,2, 5,8
from Complex Case (41)

□ A6141 Sister State Judgment 2, 5, 11

□ A6160 Abstract of Judgment 2,6
cd ©
E E Enforcement □ A6107 Confession of Judgment (non-domestic relations) 2,9
|5 -S’ of Judgment (20) □ A6140 Administrative Agency Award (not unpaid taxes) 2,8
°c «-
3
LLI O □ A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax 2,8
□ A6112 Other Enforcement of Judgment Case 2, 8,9

RICO (27) □ A6033 Racketeering (RICO) Case 1,2,8

S3
18 ~.2 □ A6030 Declaratory Relief Only 1,2,8

11 Other Complaints □ A6040 Injunctive Relief Only (not domestic/harassment) 2,8

8 (Not Specified Above) (42) □ A6011 Other Commercial Complaint Case (non-tort/non-complex) 1,2,8
£ =5
o □ A6000 Other Civil Complaint (non-tort/non-complex) 1,2,8

Partnership Corporation
□ A6113 Partnership and Corporate Governance Case 2,8
Governance (21)

□ A6121 Civil Harassment 2. 3,9

0 □ A6123 Workplace Harassment 2, 3,9
| □ A6124 Elder/Dependent Adult Abuse Case 2, 3.9
Other Petitions (Not
• -s | Specified Above) (43) □ A6190 Election Contest 2
C-£ <3 □ A6110 Petition for Change of Name/Change of Gender 2,7
* h"£
□ A6170 Petition for Relief from Late Claim Law 2.3,8
□ A6100 Other Civil Petition 2,9

LACIV109 (Rev 2/16) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3
LASC Approved 03-04 AND STATEMENT OF LOCATION Page 3 of 4

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(Page 25 of 25)

SHORT TITLE: CASE NUMBER

Robert Christopher Chatham v. Sheppard Mullin, et al.

Step 4: Statement of Reason and Address: Check the appropriate boxes for the numbers shown under Column C for the
type of action that you have selected. Enter the address which is the basis for the filing location, including zip code.
(No address required for class action cases).

ADDRESS:
REASON: 333 S. Hope Street, 43rd Floor
i 11. /12.: I 3. iJ 4. i 15.: 16.; 17. :) 8.11 9. L110.! 111.

CITY: STATE: ZIP CODE:

Los Angeles CA 90071

Step 5: Certification of Assignment: I certify that this case is properly filed in the Central District of
the Superior Court of California, County of Los Angeles [Code Civ. Proc., §392 et seq., and Local Rule 2.3(a)(1)(E)].

Dated- Febmary 26. 2018 y

(SIGNATUREfiF ATTORNEY/FILING PARTY)

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY
COMMENCE 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.
02/16).
5. Payment in full of the filing fee, unless there is court order for waiver, partial or scheduled payments.
6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a
minor 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 addendum
must be served along with the summons and complaint, or other initiating pleading in the case.

cs
rv M

C3

CC

LACIV 109 (Rev 2/16) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3
LASC Approved 03-04 AND STATEMENT OF LOCATION Page 4 of 4

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