SUPREME COURT THESTATE NEWYORK OF OF COUNTY NEWYORK OF

ADOLFO ARREOLA, JASON GOMEZ, YOLANDAMARTINE MIC APADUA. Z, CONMEGOMEZ, Plaintiffs, - against -

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X IMEXNO.:
Plaintiffsdesignate NewYork County astheplace oftial. Thebasis ofvenue is defendants' of business place andtheirexpress implied and choice ofvenue.

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TERESA GIUDICE, GUISEPPE GIUDICE, "JOEO' ALBERT JOSEPH MANZO, CHRISTOPHER THOMAS MANZO, GREGORY JOSEPH BENNETT, ALBERT JR., MA}.IZO, III, CAROLINE CLAIRE LAURITA MANZO, LAUREN MICIIELLE MANZO, STRENS idEDIe., rLC, a/r/a SIREN NYPRODCO, and, LLC., BRAVO MEDIA, LLC,acorporation,.
Defendants. To theabove named defendants:

suMMo, NS
2725 West23'd Street, Chicago, Illinois; 2726West23d Street, Chicago, Illinois; 5130 SouthNagle, Chicago, Illinois. X COUNTYOFNEWYORK

YOU ARE HEREBY SUMMONED answer complaint to the in this actionand to serye copyof your answer if the complaint not or, is served 1 with this surlmons, serve to a noticeof appearance' the Plaintiffs' Attomeys*itfri" on 20 daysafter the seryiceof this summons' exclusive qt dayof service wittrin30 days of (or afterttrere*irc is complete this if summons not personally is delivered youwithin ttresta'te New yor$: andin case your to of of failureto appear answer' judgment uetaken ttrereliefdernanded or wiit ror herein.

x'nED rH-E or couRr, il.*ligllTlsyyxsNs wAs wrrH INcrERKrHE NEWYORKCOUNTY ON COMPTIANCE

AIIID306(a). $$305(a) Dated: NewYork,Newyork June 10,201 I

WITH CPLR

217Broadway NewYork,Newyork 10007 (212)267-4t77

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13 JUN 2011 Y9S.."",nr I'IEW

Defendants' Addresses : TERESA GIUDICE GUISEPPE "JOE'GIUDICE ALBERT JOSEPH MA}IZO CHRISTOPHER THOMAS MANZO GREGORY JOSEPH BENNETT, JR. ALBERT MANZO, M
6IndianLane, Towaco, 070g2. NJ, 6IndianLane, Towaco, 07092 NJ, paterson, 02522 351West Broadway, NJ, paterson, 351West Broadway, NJ,07522 paterson, 351West Broadway, NJ,07522 351West Broadway, Paterson, 07522 NJ,

CAROLINE CLAIRE LAURITA paterson, 07j22 MANZO351West Broadway, NJ, LAUREN MICHELLE MANZO BRAVO MEDIA, LLC SIRENS MEDIA, LLC SIRENS NYPRODCO, LLC
paterson, 07522 351West Broadway, NJ, 111 Avenue, york,Newyork, l00l I 8th New 159West Sheet, Floor, 25tr 9s Newyork,Ny 10001 159 West Sheet, Floor, 25m 9h Newyork,Ny 10001

SUPREME COURT THESTATE OF OT.NEW YORK COUNTY NEWYORK Or ADOLFO ARREOLA, JASON GOMEZ, YOLANDA MARTINE MTCAPADUA, Z, CONNIE GOMEZ, plaintiffs,
- against TERESA GruDICE, GUISEPPE "JOE"GIUDICE, ALBERT JOSEPH MANZO,CHRISTOPHER THOMAS MANZO,GREGORY JOSEPH BENNETT, ALBERT JR., MANZO, III, CAROLINE CLAIRELAURITAMANZO, LAUREN MICHELLE MANZO,SIRENS MEDIA,LLC, a/r/aSIRENS NYPRODCO, and LLC, BRAVOMEDIA,LLC,a corporation, Defendants.

X INDEX NO.:

ltr

VDRIX'IED COMPI,AIISI

Plaintiffs,abovenamed, complaining the defendants, KRAME& DILLOF, of by LIVINGSTON& MOORE,ESQS., respectfrrlly allege:

l.

At all times herein mentioned, defendant sIRENs MEDIA, LLc, a/k/asIRENS

NYPRoDco, LLc, (hereinafter "$IRENS")located 159West25s Street, Floor,New at 9s York,NewYork wasandis a dulyorganized limitedliability corporation authorized to doing, business theState in ofNewyork. 2' At all timesherein mentioned, defendant SIRENSwasandis theowner, ctreator, do,andis

disuibutor,marketer, promoterand/orproducerof a televisionprogramcalled The Real Housewives N.c,Iv of Jersey airson theBravotelevision that network, whichis broadcast and in, derives revenue profitsfrom,theState and ofNew york.

3.

At all timeshereinmentioned, defendant SIRENSpurposefully transacted, and

continues Fansact, to business withinttreState NewYork and/or of confracted, continues and to conhact,to supplygoodsor services the Stateof New York and the claims in hereinare substantially related its business to and/or goods services the and provided the State New in of York. 4. At all timesherein mentioned, defendant BRAVO MEDIA, LLC, located the in

Countyof New York at 1l I 8thAvenue, New York, New York, wasandis a duly organized limitdliabilitycorporation authorized do,andis doing, to business theState Newyork. in of 5. At all timesherein mentioned, defendant BRAVO MEDIA, LLC, wasandis the

ownerand/oroperator ths Bravotelevision of network airsThe ReplHousewives New that of Jegq-eJ uponinformation beliefiparticipated continues partioipate thecreation, and and and to in distribution, marketing, advertising, promotion and/orproduction TheBeal Hgusewiyss of of NewJersev. 6. At all timeshereinmentioned, defendant BRAVO MEDIA, LLC, purposefully

tansacted, continues fransact, and to business within the State New york and/or of contracted, andcontinues contract, supply to to goods services the State New York andthe claims or in of herein substantially are related its business to and/or goods services the and provided theState in ofNewYork. 7, At all timeshereinmentioned, defendant TERESA GUIDICE wasand is a .

member thecastof of 8.

At all tirneshereinmentioned, defendant TERESA GUIDICE was and is an

agent' servant and/or employee defendants of SIRENS BRAVO MEDIA, LLc. and

9'

At alltimes herein .,JoE' GIUDICE mentioned, defendant GuIsEppE was and

is a member thecast of

10.

At alltimes r6JoE'GIUDICE and herein mentioned, defendant GUIsEppE was MEDIA,LLC.

is anagent, servant and/or employee defendants of sIRENsand BMvo I l.

At all times herein mentioned, defendant ATBERTJosEpH MANa) was and .

isamember thecast of of 12.

At all times herein mentioned, defendant ATBERTJosEpH MANzo was and

isanagent, servant and/or employee defendants of SIRENS BMVo MEDIA,LLC. and 13. At alltimes herein mentioned, defendant cHRIsTopHER III0MAS MANZO .

was is amember thecast and of of 14,

At all times herein mentioned, defendant cHRIsTopHERTHoMAs MANZO MEDIA,

wasandis anagent, servant and/or employee defendants of sIRENsandBMvo LLC. 15.

At alltimes herein mentioned, defendant GREGORY JosEpII BEIYNETT, JR. .

was is amember thecast and of of 16.

At alltimes hereinmentioned, defendant GREGoRY JosEpHBENNETT, JR.

wasandis anagent, servant and/or employee defendants of SIRENS BMVO MEDIA, and LLC. 17, At all times herein mentioned, defendant ALBERTMANzo, III was is a and

member thecastof TheRealHousewives of qfNew Jersey. 18. At all times herein mentioned, defendant ALBERT MANzo, III wasandis an

agent, servant and/or employee defendants of sIRENs andBRAVO MEDIA, LLc.

19.

At all timeshereinmentione4defendant CARoLINE CLAIRE LAURITA

I\'IANZOwasandis a member thecast TheRealHousewives NewJersev. of of of 20. At all timeshereinmenrioned, defendant cARotINE CLAIRE tAttRITA

MANZO wasandis an agent, servant and/oremployee defendants of SIRENSandB11,1VO MEDIA,LLC. 21. At all timesherein mentioned, defendant LAUREN MICHEIIE MANZO was

andis a member thecast rhe RealHousewives NewJersey. of of of 22. At all timesherein mentioned, defendant LAUREN MICHELLE MANZO was

andis anagent, servant and/or employee defendants of SIRENS BRAVOMEDIA, LLC. and 23. At all timeshereinmentioned, defendants TERESA GIUDICE, GUISEPPE

"JOE" GIUDICE, ALBERT JOSEPHMANZO, CHRISTOPHER THOMAS MANZO, GREGORYJOSEPHBENNETT' JR' ALBERT MANzo, uI, cARotINE CLAIRE

LAURTTA MANzo,TAUREN MICHELLE MANzo,sIRENs BMV0 MEDIA, and LLC., were are and parhers, agents, servants, employees other. and/or of each
24, At all timeshereinmentioned, defendants TERESA GIUDICE, GUISEPpE

6'JOE"GIUDICq ALBERT JOSEPH MANZO, CHRISTOPIMRTIIOMAS MANZO, GREGORYJOSEPHBENNETT,JR, ATBERT MANZO, III, CAROLINE CLAIRE LAURTTA MANzo, TAUREN n/flclrEl,tE MANzo, SIRENSand BRAVO MEDIA, LLC., wereandaredoingbusiness theState New York pursuant CpLRg 302based in of to on ttreiremployment andtansmission ThE for, of, RealHousewives NewJersey is broadcast of that in, andderives income, revenue profitsfrom,thestateofNew york. and

25.

hlevision pro$am deprcts certain women

,.reality" and theirfamilies ("The cast')in apr'ported setting. 26, At all timeshereinmentioned, BRAvo MEDIA, LLc, and sIRENs

encouraged, promoted, required and/or demanded Thecastof @ that Jersev engage verbal physical in and conflict oneanother withmembers thepublic, with and of thuscreating culture, a climate and/or atmosphereconfrontatioq of hostilityandviolence in order athact to viewers. 27. At all times herein mentioned, BRAvo MEDIA,LLc, andSIRENS put has

television ratings corporate and profitsoverpublicsafety. 28. In or about February 2011, of cast, upon

information and belie{,at the request defendants of BRAvo MEDIA, LLc and SIRENS taveledto theDominican Republic film scenes SEason to for Tlueeof TheRealHousewives oJ NewJersev. 29. At all timeswhile in the Dominican Republic, CastandCrewof TheReal The

Housewives NewJersev of wereemployed conholled and/or by, by acting theage,nts, as servants and/or unployees BMVO MEDIA,LLC, andSIRENS. of 30. At all timeshereinmentione.d, defendants TERESAGIuDICE, GIJIsEppE

ALBERTJOSEPH "JOE'' GIUDICE, MANZO,CHRISTOPIIER THOMAS MANZO, GREGORY JOSEPH BENNETT, ATBERTMANZO,Itr, CAROLINE JR., CTAIRE LAURITAMAI{ZO,and, LAUREN llfiCIfELtE MAN ZO, wercacting withinthescope of theiremployment and with, pusuant theirexplicit implied to and responsibilities obligations and to,SIRENS BRAYO and MEDIA, LLC.

3l'

OnFebruary 23,2011, Cast Crewwere thepremises TheMoonBar the and on of

of ttre Hard Rock Hotel & Casino, Cafe PuntaCanq ( Hard Rock - puntaCana') plaza Palmarcal BoulevardTuristicoDel Este Km. Canetera Cortechco at El #52, Higuey La Altagracia' Dominican Republic, filming scenes Season for Threeof TheRealH-o-qpewives of NewJersey. 32. On infonnation belie{ at thattime andplace,BRAVO MEDIA, LLC, and and

SIRENS demanded, encouraged promoted theCast TheReal and/or that of Housewives_of New Jersey, including defendants TERESA GIIJDICE, GuIsEppE"JoE,' GIUDICE, ALBERT JoSEPH MA'Nzo, CHRTSToPHER THoMAs MANzo, cREcoRy JosEpH BENNETT' ALBERT JR, MANZO' CAROLINE ilI' CIAIRE TAURITA MANZO, and, IAUREN lt[ICHEttE lvIANzo,drinkexcessive amounts alcohol of when knew doing it ttrat so wouldlikely leadto verbal and/or physical confrontation between Castof the TheReal

HousewivesNewJersey of and/or patrons theMoon attheHard with of Bar Rock punta Cana. 33. on or about February z].,z}fi, atapproximately a.m., l:15 defendant TERESA

GIUDICE opened bottleof champagne began a and spraying contents the around bar.As a the rcsult, the champagne sprayed defendant by TERESA GIUDICE landedon yoLANDA MARTIMZ, cawinghersevere irritationanddiscomfort. eye 34' After spraying plaintiff YOLANDA MARTINEL wrthchampagne, defendant

TERESA GIUDICE laughedat, mocked,humiliated, insultedand physicallyapproached plaintiffYolANDA MARTINEZ, such shefeared that beingbattered TERESAGIUDISE by andother members rhe castandcrew of TbqReplHousewives New of of .

35.

At that time, plaintiff ADOTFO ARREOLA tended to yOIANDA

MARTINET' andasked cast andcrew of Tlre.Real rhe pf Housewivel New Jersey cease to harming,huniliating and insulting his 53-year-old mother-irr-law, plaintiff yOLANDA MARTII\IEZ, 36. At that time, withoutprovocation, members the castand crewof lhe Rgqt of

gf.l$.ew Housewives Jerse),. including defendants TERESAGIUDICE, GIIISEpPE$JOE"

GIUIIICE ALBERT JoSEPHMANzo, CHRISToPHER THoMAs MANzo,

GREGORYJOSEPHBENNETT,JR, ALBERT MANZO, III, CAROLINE CLAIRE LAURITA MANZO, and,LAUREN n/ilCIIEtLE MANZO, physicallyattacked plaintiff ADOLF'O ARREOLA. 37. At that time,plaintiffJASONGOMEZ ran to the aid of his cousirt, plaintiff

AI)OLT'O ARREOIA. 38. ,UOE" GIIIDICE, At thattime,defendants TERESAGIUDICE,GUISDPPf,

ATBERTJOSEPHll{ANZO, CHRTSTOPIIER THOMASMANZO, cREcORy JOSEPH BENNETT,JR., ALBERT MANZO,III, CAROLINECTAIRE LAURITA MANZO,ANd LAUREN MICHELLE MANZO, alongwith ottrermembers The CastandCrewof The of Real Housewives Ne\y JeneJ,without provocation, of brutally and savagely trcat,kicked, jumped on and smashed punched, scratched, glasson the headsof plaintiffs ADOTFO ARREOLAandJA$ON GOMEZ,causing themto sustain pain severe andsuffering bodily and injwies. 39. The conduct of defendants TERESA GIIIDICE, GUISEPPE ,.JOE"

GITJDICE, ALBERT JOSEPH MANZO, CHRISTOPIIER THOMAS MANZO,

GREGORY JOSEPH BENNETT, JR, ALBERT MANZO, III, CAROLINE CTAIRE LAITRITA MANZO, and, LAUREN IIICHELLE MAIYZO, and the crew of BRAVO MEDIA' LLC' andSIRENS, engaging confrontation plaintiffsandsavagely in in with beating plaintiffsADOLFO ARREOTAandJASONGOMEZ wasdonefor thepurposes benefit and of theprogram, RealHousewiyes NewJe{Se},. The of 40. At all timesherein, defendants the TERESAGIUDICE, GUISEp|E .,JOE"

GIIIDICE, ALBERT JOSEPH MANZO, CHRISTOPIIER THOMAS MANZO, GREGORYJOSEPHBENNETT,JR, ALBERT MANZO, ilI, CAROLINE CLAIRE LAURITA MANZO, and,LAUREN MICIIELIE MANZO, wereactingwithinthescope of theiremployment andpwsuant theirexplicitandimpliedconuactual with, to responsibilities and obligations SIRSNSandBRAVOMEDIA, LLC. to, AS AND FORA FIRSTCAUSEOF ACTION FORBATTERYAI{D ASSAULT BY PTAINTIT'F ADOLI'OARREOLAAS TO DETENDANTS TERESA GIUDICE; GUISEPPE GIUDIC4 ALBERTJOSEPH MANZO; CIIRISTOPHER THOMAS "JOE" MANZO; GREGORY JOSEPH BENNETT, JR; ALBERTMANZO,il; CAROTINE CLAIRE LAURITA MANZO;LAURENMICIIELLE MANZO; SIREN$I and..BMV9 MED.IA. LLC. 41, Plaintiffs,repeat, reiterate, reallege and eachand everyatlegation contained in

paragraphs thecomplaint those of marked designated through inclusive thesame and L 40,, with forceandeffectasif herein aftersetforthat length. 42, Based defendants' on intentional conduct forth herein, set defendants TERESA

..JOF'." GIUDICE,GUISEPPE GIUDICE,ALBERT JOSEPIII\{ANZO,CHRISTOPHER TITOMAS MANZO, GREGORYJOSEPHBEIYNETT,JR, ALBERT lt{ANZO, III, CAROTINE CLAIRE LAI.ruTA MANZO, LAUREN MICI{ELLE MANZO, BRAVO

MEDIA'LLC, andSIRENS, liable plaintiffADOlFOARREOTA ttreir sre to for battery and assault against him. 43' Said occunence, incident, injuries,and damages resulting the plaintiff to

ADoLFo ARREoIA weredueto ttreintentional, deliberate, premeditated, purposeful, and wantonacts and misconduct defendants of TERESAGIUDICE, GUIsEppE sJoE" GIUDICE' ALBERT JOSEPH MANzo, cHRrsropHER THoMAs MANzo, GREG0RYJoSEPHBEIINETT,JR' ALBERTMANzo, IIr, CAR0LINE CLAIRE LAURTTAMANzo, IAIIREN ndIcIIELtE MANzo, BRAvo MEDIA, LLC, and SIRENS, theiragents, and servants and/or employeestheirensoumgement in of,promotion of, and engaging verbal physioal in, and confrontation, theirgross and indifferenceand to conscious disregard thesafety well-being thegeneral for and of public, patrons, customers, invitees guests, andothers laurfirlly the vicinityof the castandcrew,including plaintiffADOLFO in the ARREOLA.
44. By reason theforegoing, of plaintiffADOlFo ARREOLA sustained serious and

penonal injuries, including,but not limited to bluned vision, facial lacerations, bruising, scarring, disfiguement,fracturedbones, pain and sufferingand severeemotional distress: plaintiffAD0lFo ARREOLA hasbeen will continue be unable perform and to to his normal aptivities duties hassustainedresultant tlrereftom; hewascaused suffer and and a loss and to inj'ry to hisreputation livelihood, and economic losses special and damages. 45' Theamount damages of sought exceeds jurisdictionof all lowercourtsthat ttre

would othenuise jurisdiction. have

46,

Thiscause action withintheexceptionsfuticle 16of theCivilpractice of falls to

Lawand york. (CPLR) theState Rules of ofNew 47, By reason the foregoing, plaintiffADOLX'O of the ARREOLAis entitled to

compensatory darnages defendants 66JoE'GIUDICE, from TERESA GIUDICE, GUIsEppE ALBERT JOSEPH MANZO, CHRISTOPHER THOMAS MANZO, cREcoRy JosEprr BENNETTJR' ALBERT II{ANZO' UI' CAROTINECLAIRE LAURITA MANzO, LAIJREN MICHELLEMANZO, BRAVO MEDIA,LLC, andSIRENS, and/or agents, their servants and/or employees zuch in sums a jury wouldfind fair,just,andadequate, the as and plaintiffN)OLFO ARREOTA further is entitled punitive exemplary to and damages from ,.JoE" GIIJDICE,ALBERT JOSEPH defendants TERESAGIUDICE,GUISEPPE MANZO'CHRISTOPHER THOMAS MANZO,GREGORY JOSEPH BENNETT, JR., ALBERT MAltzo' III' CAROLINE CLAIRE LAURTTA MANzo, LAUREN

MICHELLEMANZO,BRAVOMEDIA,LLC, andSIRENS, theiragents, and/or seryants and/or employees such sunn a jury wouldfind fhh,just, andappropriate deter in a as to said
defendants and/ortheir agents,seryants and/oremployees ottrersfrom future similar and misconduct. AS AND FORA SECOND CAUSE ACTIONFORBATTERYAND ASSATJLT OF BY PLAINTIT'F JASONGOMEZAS TO DEFENDANTS TERESA GIUDICE; GUISSPPE MANZO; CHRISTOPIIER "JOE" GIIIDICE; ALBERTJOSEPH THOMAS MANZO; GREGORY JOSEPH BENNETT, JR; ALBERTMANZO,il; CAROLINE CLAIRE LAURTTAMANZO; LAURENMICTIELLE manzo; 48. Plaintiffs,repeafreiterate, reallege and eachand everyallegation contained in

those paragraphs thecomplaint of marked designated through inclusive thesame and l. 47., with force effect ifhereinaftersetforthat length. and as

49.

Based defendants' on intentional conduct forth herein, set defendants TERESA CHRISTOPHER

GIUDICE' GUISEPPE "JOE" GIUDICE,ALBERT JOSEPIIMANZO,

THOMAS MANzo' cREcoRY JosEPH BENNETT, JR, ALBERT MANzo, uI, CAROTINE CLAIRE TAURITA MANZO, TAUREN MICIIELLE MANZO, BRAVO MEDIA' LLC, and SIRENS,dr liable to plaintiff JASON GOMEZ for their batteryand assault against him. 50. Saidoccurrence, incident, injuries, damages and resulting theplaintiffJASON to

GOME4 were to theintentional, due premeditated, deliberate, purposeful, wanton and and acts misconduct defendants of TERESA GIUDICE, GIIIsEppErroE" GIuDICE,ALBERT JOSEPH MANZO, CIIRISTOPIIER THOMAS MANZo, cREcoRy JOSEPH BENNETT, JR, ALBERT MANzo, uI, CAROLINECLAIRE LAtruTA MAftzo, TAUREN MICHELTEII'IANZO' BRAVOMEDIA, LLC, andSIRENS, theiragents, and servants and/or employeestheirencouragement in promotion and and oS engaging verbal in, and physical confrontation, theirgross and indifferenceand to conscious disregard thesafety for and well-being thegeneral of public, patrons, customers, guests, invitees others and laudrllyin the vicinity thecastand inctuding of crew, theplaintiffJAsoN GoMEz. 51. By reason theforegoing, of plaintiff JASONGOMEZ, sustained serious and

personalinjwies, including, but not limited to facial lacerations, bruising, scarring, disfigurement, fractwed bones, ligaments, andsuffering, severe torn pain and emotional distress: plaintiffJAsoN GoMEzh:nsbeen will continue beunable perform and to to hisnormal activities andduties hassustainedresultant therefiom; he wascaused sgfferqiury and a loss and to to his reputation livelihood, and economic losses qpecial and damages.

52,

The amout of damages sought the oxceeds jurisdictionof all lowercourtsthat

wouldotherwise jurisdiction. have 53. Thiscause action fallswithinttreexceptions Article16of theCivil Practice of to

LawandRules (CPLR) theState NewYork. of of 54. By reasonof the foregoing, plaintiff JASON GOMEZ is entitledto the

I'JOE" GIUDICE, compensatory damages defendants from TERESAGIUDICE,GUISEPPE ALBERTJOSEPH MANZO,CHRISTOPHER THOMASMANZO,GREGORY JOSEPH BENNETT JR., ALBERT MANZO, fit, CAROLINE CLAIRE LAURITA MANZO, LAUREN MICHELLE MANZO, BRAVO MEDIA, LLC, andSIRENS, and/or theiragents, servants and/oremployees, suchsums a jury wouldfind fair, just, andadequate, the in as and plaintiff JASON GOMEZ is further entitled to punitive and exemplary from damages TERESA GIUDICE, GUISEPPE"JOE" GIUDICE, ALBERT JOSEPH defendants MANZO, CHRISTOPIIER THOMAS MANZO, GREGORYJOSEPHBENNETT,JR., ALBERT MANZO, III, CAROLIM CLATRE LAIruTA MAI{ZO, TAUREN

MICHELLE MANZO' BRAVO MEDIA, LLC, andSIRENS,and/ortheir agents, servants and/oremployees sucha sumas a jury wouldfind fair, just, andappropriate detersaid in to defendants and/ortheir agents, servants and/oremployees othersfrom future similar and misconduct.

L2

AS AND FORA THIRD CAUSE OX'ACTION FORBATTERYAND ASSAULT BY PLAINTIFFYOTANDAMARTINEZAS TO DEFENDANT TERESA GIUDICE; SIBFNQnnd.BRAVOII4SPIA. LLC. 55. Plaintiffs,repeat, reiterate, reallege and eachand everyallegation contained in

paragraplx thecomplaint those of marked designated ttrough54.,inclusive thesame and l. with forceandeffectasifhereinaftersetforttrat length. 56. Based defendants' on intentional conduct forth herein, TERESA set defendants

GIUDICE, BRAVO MEDIA, LLC, and SIRENS,are liable to plaintiff YOLANDA MARTINEZ for theirbattery assault and against her. 57. Said occunence, incident,injuies, and damages resultingto the plaintiff

YOLANDA MARTINEZ wasdueto the intentional, premeditated purposeful, deliberate, and wanton andmisconduct defendants acts of TERESAGIUDICE, BRAVO MEDIA, LLC, and and/or SIRENS, theiragents, employees ttreirencouragment promotion servants and/or in and of, and engaging verbaland physicalconfrontation, their grossindifference and in, and to conscious disregard the safetyand wEll-being the general public,patons, customers, for of guests, invitees otherslawfullyin the vioinityof ttrecastandcrew,including plaintiff and the YOTANDAMARTINEZ. 58. By reasonof the foregoing,plaintiff, YOTANDA MARTINEZ, sustained

serious personal and injuries,including, not limitedto severe initationanddiscomfo4 but eye blunedvision,post-taumatic pain disorder, andsuffering, severe stress and emotional distess: plaintitrYotANDA MARTINET'haIbeen will continue beunable perfonn normal and to to her activities duties hassustained and and a rcsultant therefrom; she caused zuffsrinjury loss and was to to herreputation, economic losses special and damages.

59.

The amount damages of sought exceeds jurisdictionof all lowercourtsthat ttre

wouldotherwise jurisdiction. have 60. Thiscause actionfalls withintheexceptions Article 16of theCivil practice of to

LawandRules (CPLR) ofthe State ofNewyork. 6l' By reason theforegoing, plaintiffiYOTANDAMARTINEZis entitled of the to

compensatory damages from defendants TERESAGIUDICE, BIIAVO MEDH, LLC, and SIRENS, and/or theiragents, servants and/or employees suchsums ajgry wouldfind fair, in as just, andadequate, theplaintiffYOLANDA MARTINEZ is furtherentitled and to punitiveand exemplary damages from defendants TERESA GIUDICE, BRAvo MEDIA, LLC, and SIRENS, and/or theiragents, servants and/or employees sucha sumasajury wouldfind fair, in just, andappropriate detersaiddefendants to and/or theiragents, servants and/or employees, and others fromfuturesimilarmisconduct.

GRossNEGLIGENCE, cARELEssNEss REcKLEssMsSBy AIYD PLAINTII'X'ADOLFO ARREOLA TO AS DEFENDANTS SIRENS: BRAVO and. MEDL{ LLC. 62.

AS AI\[DFORA TOURTHCAUSE ACTIONFORMGLIGENCE, OF

Plaintiffs, repeat, reiterate, reallege andevery and each allegation contained in

paragraphsthecomplaint those of marked designated and l. tt'ough61.,inclusive thesame with force effect if herein set and as after forttr length. at 63. Based defendants' on conduct forthherein, negligence, negligence set the gross

careless and/or reckless andconduct defendants acts by SIRENS, BRAV0 MEDIA, LLc, and and/or their agents, servants and/or employees the directandproximate were cause plaintiff of AI)OIFO ARREOLA'sinjuries.Defendants' and/or theiragents, servants and/or employees

14

conduct, and/or acts omissiorn a breacheddutyof oare theplaintiffAD0tFO ARREOLAand to thegeneral publicthatrcsulted injtuies were thar in foreseeablea reasonable person. to 64. As a result tlreforegoing plaintiffADOlF0 ARREOLA sustained of serious and

personal injuries, including,but not limited to bluned vision, facial lacerations, bruising, scaning disftgurement, pain and suffering,and severe fractued bones, ernotional distress: plaintiffADOTFO ARREOLA hasbeen will continue be unable perform normal and to to his activities duties hassustainedresultant therefrom; hewascaused sufer injury and and a loss and to to hisreputation livelihood, and losses special economic and damages. 65. Said occunenoe, incident,injuries, and damages resultingto the plaintiffl

ADOLX'OARREOLA,wasduetrothc knowing, negligent grossly wanton, reckless, negligent, and careless misconduct defendants BRAVO MEDIA, LLC, and SIRENS,and/orfteir of agents, servants in and/oremployees their encowagement promotion andengaging of, of, in, verbal physical and confrontation, theirgross and indifference anddisregard thesafety to for and well-being tlrc general public,paFons, guests, of invitees others customers, and lawfullyat The MoonBarattheHardRock- Punta Cana, ttre including plaintiffAD0tFO ARREOLAwith no faultor lackof care thepartof theplaintiff. on 66. By reason the foregoing, plaintifi ADOLFO ARREOLA is entitledto of the

compensatory damages from defendants BRAVO MEDLA, LLC, and SIRENS,and/ortheir agents, servants and/or employees such in sums ajury wouldfind fair,jus! andadequate, as and theplaintiffADOLFOARREOLAis further entitled punitive exemplary to and damages from defendants BRAVO MEDI{ LLC, and SIRENS, and/or their agents,servants and/or

15

ernployees sucha sumasajury wouldfind fair,just, andappropriate detersaiddefendants in to and/or theiragents, sewants and/or employees others and fromfirturesimilarmisconduct. 67. The amount damages of sought exceeds jurisdictionof all lowercourtsthat ttre

wouldothenvise jurisdiction. have 68. Thiscause action of falls withintheexceptions Article 16of theCivil practice to

LawandRules (CPLR) theState Newyork. of of GROSS MGLIGENCE, CARELESSNESS RECKTESSNESS ANI} BY PLNNTTFFJASONGOMEZAS TO 69,

As ANDFoRFnrrH CAUSE AcTIoNFoRIYEGLIGENCE, or

Plaintiffs,repeat, reiterate, reallege and eachand everyallegation contained in

paragraphs thecomplaint those of marked designated througb inclusive thesame and l. 68., with forceandeffectasif herein aftersetforthat length. 70. Basedon defendants' and conduct forth herein,the negligence, acts set gross

negligence careless and/orreckless conduct defendants by SIRENS,and BRAVO MEDIA, LLC, and/ortheir agents, servants and/oremployees, the directandproximate were cause of plaintiff JASON GOMEZ's injuries. Defendants' and/or their agents,servants and/or employees conduct, actsand/oromisionsbreached duty of careto the plaintitr JASON a GOMEZ andthe general publicttratrezulted injrries that wereforeseeable a reasonable in to pennn. 71. As a resultof the foregoing, plaintiff JASON GOMEZ, sustained serious and

personalinjuries, including, but not limited to facial lacerations,bruising, scarring, disfigr[ement, fractured bones, ligaments, andsuffering severc torn pain and emotional dishess: plaintiffJASoNG0MDzhasbeen will oontinue beunable perform nonnal and to to his activities

andduties hassustainedresultant therefiom; and a loss andhe wascaused sufferinj'ry to his to repuhtion livelihood, and economiclosses special and damages. 72' Saidoccunence, incident, iqiuries, daurages and resulting theplaintiffJASoN to

GoMEz' wasdueto theknowing, negligent, wanton, reckless, grossly negligent, careless and actsand misconduct defendants of BRAV0 MEDIA, LLc, and SIRENS,andtheir agents, servants and/or employees theirencouragement promotion andengaging in of, ofl in, verbaland physical confrontration, theirgross and indifference anddisregard thesafety well-being to for and of thegeneral public,pahons, custome$, guests, invitees others and lawfullyat TheMoonBarat ttreHardRock- Punta cana including plaintiffJAsoN GoMEz, with no fault the or lackof caro thepartof theplaintiff on 73' By reason the foregoing, plaintiff JAsoN GoMEz of the is entitledto

compensatory damages defendants from BRAvo MEDIA, LLc, andsIRENS, and/or their agents, servants and/or employeessuch in sums ajwy would fair,just,and as find adequate, and theplaintiff JAsoN GoMEz is further entitled punitive exemplary to and damages from defendants BRAvo MEDIA' LLc, and SIRENS,and/ortheir agents, servants and/or employecssuch sum ajury would fair,just,and in a as find appropriatedeter defendants to said and/or agents, their servants and/or employees others future and from similar misconduct. 74' Theamount damages of sought exceeds jurisdiction all lower the of courts that

wouldotherwise jurisdiction. have 75' Thiscause aption withintheexceptions Article16 of falls to of theCivil practice

LawandRules (CPLR) theState of ofNew york.

L7

AS AND F'OR SI}ffH CAUSE A OT'ACTIONFORNEGLIGENCE, GROSS NEGTIGENCE, CARELESSNESS RECKLESSNESS AI\D BY PLAINTIFF YOTANDAMARTINEZ AS TO DE{4ND"AIITS,SIRENST BRAVOMEDIA. L"_LG and. 76. Plaintiffs,repeat, reiterate, reallege and eachand everyallegation contained in

paragraphs thecomplaint those of marked designated through inclusive thesame and L 75., with forceandeffectasif herein aftersetforthat length. 77. Basedon defendantso and conduct forth herein,the negligence, acts set gross

negligence careless and/orreckless conduct defendants by SIRENSand BRAVO MEDIA, LLC, and/ortheir agents, servants and/oremployees werethe directandproximate cause of plaintiff VOTAI\IDAMARTINEZ's injuries. Defendants' and/or ttreiragents, servants and/or employees conduct, and/or asts omissions breached dutyof careto the plaintiffYOLAITDA a MARTINEZ andthegeneral publicthatresulted injuries wereforeseeablea reasonable in that to person. 78. As a result theforegoing, plaintiff,YOLANDA MARTINEZ, sustained of serious

andpersonal injuries,including, not limitedto severe initation, blunedvision,post, but eye haumatic sfiess pain disorder, andsuffering severe plaintiffYOLANDA and emotional disfiess: MARTIMZhas been will continue beunable perform normal and to her to activities duties and andhave sustainedrcsultant tlrerefrom; shewascaused suffer a loss and to injuryto herreputation andlivelihood, economis losses special and damages, 79, Said occunence, incident,injuries, and damages resultingto ttre plaintiff,

YOLAFIDA MARTINEZ was due to the knowing,negligenf,wanton,reckless, grossly negligentandcareless misconduct defendants of BRAVO MEDIA, LLC, andSIRENSand theiragents, servants and/or employees theirencoruagement promotion andengaging in of, ofl

in, verbalandphysical oonfrontation, theirgross and indifference anddisregard thesafety for to andwell-being the general public,patrons, of customers, guests, invitees others and laufirlly at TheMoonBarat theHardRock- Punta including plaintiffYOLANDA MARTINEZ the Cana" with no faultor lackof care thepartof theplaintiff. on 80. By reason theforegoing, plaintiffY0tANDA MARTINEZis entitled of the to

compensatory from defendants damages BRAVO MEDIA, LLC, and SIRENSand/ortheir agents, senants and/or employees such in sums ajury wouldfind fair,just, andadequate, as and ttreplaintiff YOLANDA MARTINEZ is furtherentitledto punitiveaudexemplary damages from defendants BRAVO MEDIA, LLC, and SIRENSand/ortheir agents, servants and/or employees sucha sumasajury wouldfind fair,just, andappropriate detersaiddefendants in to and/or theiragents, selTants and/or employees others and fromfuturesimilarmisconduct. 81. Theamount damages of exceeds jwisdictionof all lowercourts sought the that

wouldotherwise j urisdiction. have 82. Thiscause action of fallswithintheexceptions Article16of theCivil Practice to

(CPLR) theState NewYork. LawandRules of of AS AND FORA SEVENTH CAUSE ACTIONFORLOSSOF SERVICES OF BY PLAINTIFFNIICAPADUAASTO DEFENDANTS TERESAGIUDICE;GUISEPPE (JoE" GIUDICE;ALBERT JOSEPII MANZO;CHRISTOPITER TH0MAS MANZO; GREGORY JOSEPH BENNETT JR";AIBERT MANZO,III; CAROLINECTAIRE LAURITA MANZO; TAT'RENMICHELLE MANZO; gl.BFlig.i, rgd, BMVO MEDIA. LLC. 83. Plaintiffsrepeat, reiterate, reallege and eachand everyallegation contained in

paragraphs thecomplaint those of marked designatedttuough82.inclusive, thesame l. and with forceandeffectasif hereinafter forthat length. set

19

84.

At all timesherein plaintiffMlCA PADUA wasmaniedto plaintiff mentioned,

ADOLFOARREOLA. 85. By reason ttreforegoing, plaintiffMlCA PADUAwasdeprived thesewices of of

plaintiff ADOLX'OARREOLA andwascaused become of her husband to obliged expend to sums money medical hospital onhis behalf. of for and care 86. The amount damages of sought exceeds jurisdictionof all lowercourtsthat the

wouldothenroise jurisdiction. have AS AND FORAN DIGHTHCAUSE ACTIONT'OR LOSSOF SERVICES OF BY PLA'INTIFT CONNIEGOMEZASTO DEFENIIANTS TERESAGIUDICE;GUISEPPE 'fJOE" GIUDICE;ALBERTJOSEPH MANZO;CHRISTOPHER THOMASMANZO; GREGORY JOSEPH BENNETT JR.; ALBERTMANZO,ill; CAROLINECLAIRE LAIruTA MANZO; TAURENMICI{EILE MANZO; end.BRAVOMEDIA. LLC. SIREN$: 87. Plaintiffsrepeat, reiterate, reallege contained and eachand everyallegation in

paragrapls thecomplaint those of marked designatedthrough inclwive,with thesame and L 86. forceandeffectasifhereinafter forthat length. set 88. At all timeshereinmentioned, plaintiff CONNIf, GOMEZ was maniedto

plaintiffJAsONcOMEz. 89. By reason the foregoing, plaintiff CONME GOMEZ was deprived the of of

plaintiffJASONGOMEZandwascaused become seryices herhusband of to obliged expend to sums money medical hospital onhisbehalf. of for and care 90. The amount damages of sought exceeds jurisdictionof all lowercourtsthat the

wouldotherwise jurisdiction. have

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91.

To t y to avert the clear liability and exposure resultingfrom their conduct

towardsplaintiffs ADOLFO ARRD0LA and JASoN GOMEZ on Febrrrary 201, 23, defendans' lawyers and/or their representatives prepared Settlement a Agreement Release and that plaintiffs ADOLX'O ARREOLA and JASON GOMEZ were forced to sign. This settlement Agreement Release attached and is hereto Exhibit,.A',. as 92. This document signedby plaintiffs ADOTF'OARREOI"A and JASON was

GOMEZ at the policestation, prior to receiving needed propermedical and attention, within (72) hours of the incidentcomplaiued under great coercion, seventy-two of, duressand emotional sttess, plaintiffsADOTFO ARREOLA andJASON GOMEZ were as told that if they did not sign the release, neitherthey, nor their families,would be able to leavethe Dominican Republic. 93. Fearingfor the safetyof themselves their families,and needing and quality

medical andattention theUnited care in States, signed release they the forced uponthem. 94. Amongst otherthings,this Settlement Agreement Release, and draftedby, for,

and/or behalf defendants, anattempt deny on of, is plaintiffstheirrightsfor theharmthatthey to suffered February23, 2011,as a resultof defendants' on heinous, improperand shocking conduct. 95. Specifically, paxasaphs and2 of the Settlement I Agreement Release and limits

the recovery plaintiffsADOLFO ARREoIA andJASoN GoMEz for their injuriesand of damages from the February23, 2}ll incident desuibedherein to $25,000.00, plus

reirnbursement of medical costs expenses to $12,000.00 $2,500.00 plaintiffs and up and for ADoLF'oARRE0IA and JASON GoMEZ's aggregate outside counsel costs. 96. In paragraph of the Settlement 3 Agreement General and Release, plaintiffs

ADOTX'OARREOLA and JASON GOMEZ were forced to providea full release for themselves and their spou$es, children and others to defendants TERESA GIUDICE, ffJOE" GIITDICE, GUISEPPE ALBERT JOSDPH MANZO, CHRISTOPIruR THOMAS MAltzo, GREGORY JOSEPHBENNETT, JIt, ALBERT IVIANZO,UI, CAROTINE CLAIRE tAURrrA MANzo, TAUREN IIICHELLE MANzo, BRAvo MEDIA, LLc, and'SIRENS,andmanyotherreleasees, including their agents, servants and/or employees, for all claimsarisingout of, andat anytime prior to, the February 23,2011incident, any so4 of knownor unknown, suspected unsuspected. or 97, In paragraph of the Settlement 5 Agreement General and plaintiffs Release,

ADOLFO ARREOLA andJASONGOMEZ wereforcedto agree theywererelyingon ttrat ttrgirownjudgment, not of anyphysiciaqsurgeon oilrerindividualthatmayhavebeen and or employed, assess injuries, to prugnosis their and/or recovery therefrom. 98. In paragaph6 of the Settlement Agreement General and plaintiffs Release,

ADOIFO ARREOLA qnd JASON GOMET' werc forcedto agreethat they would keep confidential February the 23,2011incident, iqjuriesttrerefrom termsandconditions the and in theSettlement Agreement. 99. Paragraph of theSettlement 10 Agreement General and Release requires plaintiffs

ADOLFOARREOLA andJASONGOMEZto agree mediate thenarbitrate claims to and any

22

arisingout of or relatingto the settlement agreement, agreements the incorporated the into settlement agreement thebreach anytermthereof. or of 100. Paragraph of thE Settlement l0 Agreement Release and draftedby defendants furtherprovides ilre "internal, that substantive of the Stateof New York" applyandthat laws disputes beresolved shall inNewYork,NewYorkor Chicago, Illinois. l0l. Defendants availed have themselves thisCorrt'sjurisdiction chosen be of and to

bound thelawsandstatutes theState by of ofNew York. 102. Further, paragraph of the Settlement 12 Agreement General and Release claims ttratplaintiffsADOLFO ARREOLAandJASONGOMDZwereauthorized execute, be to and bound ttreSettleurent by, and Agreement thattheywererepresented counsel alsosigned by who theagreement approval its terms evidence legalassistance guidance as and of and of through the process. 103. However, this release was signedby plaintiffsADOTFO ARREOLA and JASONGOMEZ undergreatduress, coercion physical emotional and and shess, setforth as herein. 104.' Upon information belief,therewas a conspiracy and between defendants, tlrc Punta Canapolice,the Magistrate, HardRockCafe- PuntaCanaandthe lawyerassigned to plaintiffsADOLFO ARREOLAandJASONGOMEZ,wherein plaintiffswereforced waive to their rightsandcounsel forceduponthemso that theyandtheir familiescouldleavethe was Dominican Republic.

23

105. Plaintiffs ADOLFOARREOLAandJASONGOMEZwere represented not by independent counsel relating to the SettlementAgreementand Releaseand prior communications thereto. 106. Therepresentations in paragraph of theSettlement 12 Agreement Release and are a sham. 107. PlaintiffsADOLX'OARREOLA and JASON GOMEZ lnve not cashed the checks relating theSettlement to Agreement Release. and AS AND FORA NIMH CAUSEOF ACTION X'OR INTENTIONAL AND/OR NEGTIGENT INFIICTION OF EMOTIONALDISTRESS PLAINTII'T'ADOLI'O BY c.JOE'' ARREOLAAS TO DEFENDAMSTERESA GIUDICE;GUISEPPE GIUDICE; ATBERTJOSEPH IVIANZO; CHRISTOPHER THOMASMANZO; GREGORY JOSEPH BENNETT JR.; ALBERTMANZO,III; CAROTINECLAIRE LAT,RITAMANZO;TAURENMICHELLE MANZO; SIRENST BMVO MEDIA., LlC.' and. 108. Plaintiffs, rcpeat, reiterate, reallege and eachandeveryallegation contained in paragraphs the complaint those of marked designated through and l. with the 107.,inclusive same forceandeffectasif herein aftersetforthat length. 109. Defendants forcingplaintiff ADOLFO ARREOL.A. waivehis legalrightsso to thatheandhis familycouldretumsafely tlreUnitedStates themedical thatheneeded to for care is exfiemeand oufiageous, intended cause was to harmor was in disregard a substantial of probabilityof causing harmand severe emotional disftess, resulted severe and in emotional distess. ll0. 6,JOE" Based the foregoing, on TARESAGIIIDICE, GUISEPPE defendants

GIUDICE, ALBERT JOSEPH MANZO, CHRISTOPITERTHOMAS MANZO, GREGORYJOSEPHBENNETT,JR, ALBERT MANZO, UI, CAROLINE CLAIRE

IAURITA MANzo, TAURENnilIcHEtLE MANzo, BRAvo MEDIA, LLC, and sIRENs, and/or their agents, servants and/or employees liableto plaintiffADoLx,O are ARRE0IA forintentional and/or negligent infliction emotional of dishess. I I I' Theamount damages of sought exceeds jurisdiction all lowercowts the of that

would othenvise juisdiction. have ll2' Thiscause action within exceptionsArticle16of theCivilpractice of falls tlre to

Lawand (CPLR) theState New Rules york. of of By reason theforegoing, plaintiffADOLF'O of the ARREOLA entitled is to compensatory damages defendants from TERESA GIUDICE, GUISEPPE "JOE" GIUDICE, ALBERT JOSEPH MANZO, CHRISTOPHER THOMAS MANZO, cREcoRy JosEpH BENNETTJR' ALBERT MANZO' III' CAROLINECLAIRE LAURITA MAttZO, LAUREN ndICHEttE MANZO, BRAVO IVIEDIA, LLC,and SIRENS, and/or agents, their servants and/or employees such in sums ajury wouldfind fair,just,andadeqgate, the as and plaintiffADOTFOARREOTA further is entitled punitive exemplary to and damages from ..JOE" GIIJDICE,ALBERT defendants TERESAGIUDICE,GUI$EPPE JOSEPH MANa)' CIIRTSTOPIIIR THOMAS MANzo, GREGORY JosEpH BENNETT, JR, ALBERT MANZO, III, CAROTINE CLAIRE LAURITA MANZO, LAUREN MICHELLEMANZO,BRAVOMEDIA, LLC, andSIRENS, and/or theiragerus, servants
and/oremployees sucha sumas a jury wouldfind fair, jusf andappropriate in to detersaid defendants and/ortheir agents, servants and/oremployees othersfrom fufure similar and misconduct.

ll3'

25

GOMEZ TODETENDANTS AS .TOE,, TERESA GII]DICE; GTIISEPPE GIUDICE; ALBERT JosEpIIMANZO; cHRIsropIIERTHoMAs ruANZo; cREcoRYJ0SEPH BENNETT AtBEnr ulrvzo, III; cARotINE cLAIRE JR.; LATJRITA
IVIANZO; LATJREN MICIIELLE MANZq Ll4' Plaintiffs,repeat, reiterate, reallege and eachand everyallegation contained in

AND/OR NEGLIGENT INFtIcTIoNoFEMorrorur, orsiRrss BypLArNTrrF JAsoN

ASANDFORA TENTIICAUSE ACTIONFORINTENTIONAI OF

those paragraphs the complaint of mukedanddesignate.dthrough113.,inclusive l. with the same forceandeffectasif herein aftersetforthat length. 115' Defendants forcing plaintiffJAsoN GoMDZtowaivehislegalrights thathe so andhis family couldreturnsafelyto the UnitedStates the medical for carethathe needed is exhemeand ouhageous' intended cause was to harm or was in disregard a substantial of probabilityof causing harmand sever emotional distress, resulted severe and in emotional distress. 116. Based the foregoing, on f.JoE" defendants TERESAGIIIDICE, GUISEPPE

GIUDICE'ALBERT JosEPH MANzo, cHRIsropHER TIIoMAS MANz,o,

GREGORYJOSEPH BENNETT' JR, ALBERT MANZO, III, CAROLIIYE CLAIRE LAURITA MAI\ZO, LAUREN MICIIELLE l\,IANzO, BRAVO MEDIA, LLC, and SIRENS, and/or theiragents, sewants and/or employees liableto plaintiffJAsoN GOMEZ are for intentional and/or negligent inflictionof emotional distess. ll7 ' Theamount damages of sought exceeds jurisdictionof all lowercourtsthat ttre

wouldothenvise jwisdiction. have 118' Thiscause action of fallswithintheexceptions Article16of theCivil practice to
Law andRules(CPLR)ofthe State ofNew york.

26

119. By reasonof the foregoing, plaintiff JASON GOMEZ is entitledto the compensat'ory danages fromdefendants TERESAGIUDICE, CUISEPPE "JOE" GIUDICE, ALBERT JOSEPHMANA), CHRTSTOPHER THOMASMANA), GREGORY JOSEPH BENNETT JR", ALBERT MANZO, UI, CAROTINE CLAIRE LAURITA MANZO, LAUREN MICIIEILE MANZO, BRAVO MEDIA, LLC, andSIRENS, and/or theiragents, sewants and/oremployees suchsums a jury wouldfind fair, just, andadequate, the in as and plaintiff JASON GOMEZ is further entitledto punitive and exemplarydamages from defendants TERDSA GIUDICE, GIJISEPPEf{JOE GIIJDICE, ALBERT JOSEPH MANZO, CHRISTOPHERTHOIUASMANZO, GREGORYJOSEPHBEFTNETT, JR, ALBERT MAI\ZO, III, CAROTINE CLAIRB LAIruTA MAIYZO, LAUREN

MICIIELLE MANZO, BRAVO MEDIA, LLC, andSIRENS,and/ortheir agents, servants and/oremployees sucha sumas a jury wouldfind fair, just, andappropriate detersaid in to defendants and/orttreir agents,servants and and/oremployees othersfiom future similar misconduct. AS AIYDFORELEVENTH CAUSEOX'ACTIONTO DEEM FITJLL AND VOID AND TO RESCINDTI{E SETTIEMENT AND RETEASE PLAINTIFF ADOLFOARREOLA BY f'JOE" GITJDICE; AS TO DEFENDAI\TS GUISEPPE ALBERTJOSEPH MANZO;CHRISTOPIIER THOMASMANZO; GREGORY BENNETT JOSEPH JR; ATBERTMANZ;0,I[; CAROLINECLAIRE LAT,RITAMANZO; TAURENMICHELLE MANZO; SIRDI{$iaR4. F,BAJQMEDIA. LLC. 120. Plaintiffs,rpeaL reiterate, reallege and eachand everyallegation contained in paragraphs the complaint those of marked designated through119.,inclusive and l. with the same forceandeffectasif herein aftersetforthat length.

27

I2l'

To try to avertthe clearliability andexposure resulting fromtheir conduct

towards plaintiffADolFO ARREOLA February on 23,2011, defendants' lawyers and/or their representatives prepardsettlement a agreement release plaintiffADolFo ARREoIA and that was forced sign. to 122- Paragraphs 2 limit therecovery plaintiffADotFo ARREoLA I and of for his injuries damages ttreFebruary and from 23,2011 incident described to $2j,000.00, herein plus reimbursement of medical costs expenses to $12,000.00 $2,500.00 his and and up and for plaintiffJAsoN GoMEZ's aggregate counsel outside costs. 123' In paragraph of ttreSettlement 3 Agreement Release, and plaintiffADOLpO
ARRDoIA wasforcedto providea full release themselves their for and sporses, childrcnand others to defendants TERESA GIUDICE, GUIsEppE ..JoE', cruDIcE, ALBERT

JOSEPH MANZO, CTIRISTOPIMR THOMAS MANZO, GREGORY JOSEPH BENNETT' JR' ATBERT MAI{ZO' III' CAROTINE CTAIRE TAURITA MANZO, LAUREN MICHETLE MANZO' BRAVO MEDIA, LLC, and SIRENS, andmanyother releasees, including their agents, servants and/or employeeq all claimsarising of, andat for out anytimeprior to, the February 23,2011incidurt,of anysort,knownor rrnknown, suspected or unsuspected. 124' This release signed plaintiff ADotFo ARREoIA within was by seventy-two

(72)hours theincident of complained under of, great duress physical emotional and and shess, asplaintiffADolF'OARREOTA toldthatif hedidnotsrgn release, was the neither norhis he, family, would able leave Dominican be to the Republic.

28

125- Fearing ttresafety himselfandhis family,andneeding for of qualitymedical care andattention theunitedstrates, signed release in he the forced uponhim. 126. Based the severe significant on and injuriesof plaintiff ADOTFOARREOTA for whichhe wastrot evenallowedto, nor permittod receive to, advicefrom an independent

doctoror lawyer,prior to signingthe settlement release, settlement and the and rclease is unconscionablea matter law. as of 127. Based theforegoing, on paxagaphs 2 and3 of this release l, described herein are void anda nullity andarerescinded plaintiff requests this Courtadjudicates as and that them such.

128, Theamount damages of sought exceeds jurisdiction all lower the of courts that would othenvise jurisdiction. have 129, Thiscause action withintheexceptionsArticle16of theCivitpractice of fatls to Lawand Rules (CPLR) theState of ofNewyork. ASANDFORA TWETFTH CAUSE OT'ACTION DEEMNUIL ANDVOIDANI) TO TORESCIND THESETTLEMENT RELEASE PLAIMITT JASON AND BY GOMEZ (.JOE" ASTODEX'ENDAMS GTIISEPPE GIUDICE; ATBERT J0SEPH MANZo; cHRIsropHER THOMAS MANZO; GRDG0RY JOSEPH BENNETT ALBERT JR; MAI{zo, trt; cARotINE SLAIRE LAURITAMAN?,O; LAUREN MICHELLEMAITIZO; SIREN,S: B4AVOMEDIA. and. LLC. 130. Plaintiffs, repeat, reiterate, reallege andevery and each allegation contained in
thoseparagraphs ttre complaint of marked designated tluough 12g.,inclusive and l, with the same forceandeffectasif herein aftersetforthat lengh. 131. To try to avertthE clearliability and exposure resulting from their conduct plaintiff JASON GOMEZ on February towards 23,2011,defendants' lawyers and/or their

prepared settlement representatives a and agreement release plaintiffJAs0N GOMEZwas that forced sign. to 132. Paragraphs and 2 limit the recovery plaintiff JASON GOMEZ for his I of injuries damages theFebnrary plus and from 23,2011 incident described heroin $25,000.00, !0 reimbursement medical costsandexpenses to $12,000.00 $2,500.00 his and up of and for plaintiffADOLI'O ARREOLA'saggregate counsel costs. outside plaintiff JASON 133. In paragraph of ttre Settlement 3 and Agreement Release, GOMEZ wasforcedto providea full release ttremselves their spouses, and childrenand for TERESA GIUDICE, GUISEPPE 'UOE" GIUDICE, ALBERT others to defendants JOSEPTI MANZO, CHRISTOPITER THOMAS MANZO, GREGORY JOSEPH BENNETT, JR", ALBERT MANZO, tII, CAROITNE CLAIRE LAURITA MANZO, LAIIREN MICIIELLE MANZO, BRAVO MEDIA, LLC, and SIRENS,andmanyotlrcr theiragents, employees, all claimsarising of, andat rcleasees, including for out servants and/or anytimeprior to, the February swpected 23,2011incident, anysort,knownor unknown, or of unsuspected. (72) 134, This release signed plaintiff JASON GOMEZ within seventy-two was by hoursof the incidentcomplained undergreatduress of, and stress, as and,physical emotional plaintiffJASONGOMEZ wastold tlnt if hedid not signtherelease, neither norhis family, he, wouldbeableto leave Dominican the Republic. 135. Fearing thesafety himselfandhis family,andneeding qualltymedical for of care in andattention theUnitedStates, signed release he forced the uponhim.

30

135. Based the severe significant on and injruiesof plaintiffJASONGOMEZ for whichhe wasnot evenallowed nor permitted receive to, to, advice from an independent doctor or lawyer, prior to signing tlre settlement and rclease,the settlsmentand releaseis unconscionablea matter law. as of 137- Paragraphs and3 of ttrisrolease 1,2 described herein void anda nullityand are arerescinded plaintiffrequests thisCourtadjudicates assuch. and ttrat them 138. The amount damages of exceeds jurisdictionof all lowercourtsthat sought the wouldotherwise jruisdiction. have 139. Thiscause action withintheexceptions Anicle t6 of theCivil Practice of falls to LawandRules (CPLR) theState NewYork. of of AS AI{D FOR A THIRTEENTHCAUSEOF ACTION FOR SETTINGASIDE TIIE COMII}ENTIALITY PROVISIONS PTAINTIFFADOTFOARREOLAASTO BY .,JOE' GIUDICE;ALBERTJOSEPH DEFENDANTS TERESA GIT]DICE; GUISEPPE MANZO; CHRISTOPIIERTHOMAS MANZO;GREGORY JOSEPH BENNETT JR; ALBERT IVIANZO, CAROLINECLAIRE LAURITA MANZO; LAT,REN III; MICHEILE MAN?O: SIR4![S:md. BRAVg.MEDIA.LLC. 140. Plaintiffs,repeatreiterate, reallege and eachand everyallegation in contained thoseparagraphs the complaint of marked designated ttuough139.,inclusive and 1. with the forseandeffectasif herein same aftersetforthat length. 141. To try to avert the clear liability and exposure resultingfrom their conduct towards plaintiffADolF0 ARREOLAonFebruary 23,2011, defendants' lawyers and/or their representatives prepareda Settlement Agreementand Releasethat plaintiff ADOLFO ARREOTAwasforcedto sign.

31

142. In paragraph of the Settlement 6 Agreement Release, and plaintiff ADOLFO ARREOTAwasforced agree hewouldkeep to that confidential February ttre 23,Z0ll incident, theinjuries therefrom terms conditions theSettlement and and in Agreement. 143. Thisrelease signed plaintiffAD0ll'O ARREOLAunder was by great coercion, duress physical emotional and and stess,assetforthherein. 144, Based the foregoingparagraph of the Settlement on 6 Agreement Release and is void anda nullity andplaintiffADOtFO ARREOLArequests this Counadjudicates as that it such. 145. Theamount damages of sought exceeds jurisdiction all lowercourts the of that wouldotherwise jurisdiction. have 146. Thiscause actionfallswithintheexceptions Article 16of ttreCivil praptice of to (CPLR) theState LawandRules of ofNew york. AS ANI} FORA FOURTEENTH CAUSE ACTIONFOR SETTING OF ASIDE THE CONI'IDENTIATITYPROVISIONS PLAINTIFFJASONGOMEZAS TO BY DEFENDANTS TERESAGIUDICE;GUISEPPE "JOE" GIUDICE;ALBERTJOSEPH MANzo; CHRISTOPIfiR THotuAs MANZ0; cREGoRy JosEpH BENNETT JR; ALBERT MANZO,il; CAROTINECLAIRE LAURITA MANZO; TAUREN and. MJC4EILE MANZO:.$"IRENS: BRAyO MEDIA. LI,.F. 147. Plaintiffs,repea!reiterate, reallege and eachand everyallegation contained in paragraphs the complaint those of marked designated through and 1. 146.,inclusive with the same forceandeffectasif herein aftersetforthat length. 148. To try to avertthe clear liability and exposure resultingfrom their conduct plaintitrJASON GOMEZ on February towards 23,2011,defendants' lawyers and/or their representatives prepared Settlement a Agreement Release plaintiff JASONGOMEZ and that wasforced sign, to

plaintiff JASON 6 149, In paragraph of the Settlement Ageementand Release, GOMEZ wasforcedto agree he wouldkeepconfidential Febnrary that ttre 23,2011incident, and and in theinjuies ilrerefrom terms conditions theSettlement Agreement. 150. This release signed plaintiff JASON GOMEZ undergreatcoercion, was by duress physical emotional and stress, setforthherein. and as paragraphof theSettlement and is Agreement Release 151. Based theforegoing, on 6 it voidanda nullity andplaintiffJAS0N GOMEZrequests tlris Cowtadjudicatesassuch. that sought the of excoeds jwisdictionof all lowercourtsthat 152, The amount damages would ottrerwise jwisdiction. have to fallswithintlreexceptions Article16of theCivil Practice 153. Thiscause action of (CPLR) LawandRules ofNewYork. oftheState OF AS AND FORA FIFTEENTH CAUSE ACTIONFORSETTINGASIDE BY THE ARBITRATIONAND MEDIATION PROVISIONS PLAINTIF'FADOLFO *JOE, GITJDICE; TERESA ARREOLAAS TO DEFENDANTS GII'DICE; GUISEPPE JOSEPH ATBERTJOSEPH MANZO;CHRISTOPIIER TIIOMAS MANZO; GREGORY BENNETTJR; ALBERT lUANzO,III; CAROTINECLAIRE tAtruTA MANZO; qnd. LAIIREN MIQI{ELLE MANZO:SIRENST BRAVQ,MEDIA. LIIC. 154. Plaintiffs,repeat, reiterate, reallege eachand everyallegation conainedin and thoseparagraphs the complaint l. with the marked designated through153.,inclusive of and forceandeffectasif herein same aftersetforthat length. 155. To try to avert the clear liability and exposure resultingfrom their conduct plaintiffADOIF'OARREOLAon February lawyers towards 23,2011, and/or defendants' their prepareda Settlement representatives Ageement and Releasettrat plaintiff ADOTFO ARREOLAwasforced sign. to

33

156. Paragraph of that document l0 requires plaintiff ADoLFo ARRE0LA to mediate thenarbitrate claimsarisingout of or relating the settlement and any to agreement, the agreements incorporated thesettlement into agreement thebreach anytermthereof. or of 157. Thisrelease signed plaintiffADolI'O ARRDOTAunder was by great coercion, duress physical emotional and and sfress, setforthherein. as 158. The provisions paragraph of the Settlement of 10 Agreement Release and mandating dispute resolution mediation arbihation void anda nullity andplaintiff by and are requests ttrisCourtadjudicatesassuch. that it 159. Theamount damages of sought excecds jurisdiction all lowercourts the of that wouldotherwise jurisdiction. have 160. Thiscause action of fallswithintheexceptions Article16of theCivil practice to LawandRules (CPLR) ttreState Newyort. of of AS AND FOR A SIXTEENTHCAUSEOF ACTION FOR SETTINGASIDE THE ARBITRATIONAND MEDIATIONPROVISIONS PTAINTIFFJASON BY GOMEZAS TO DEX'ENDANTS TERESA GIUDICE;GUISEPPE.6JOE' GIIJDICE; ATBERTJOSEPH MANZO;cHRrsTopHER THoMAs MANZO; GREGORY JOSEPH BENMTT JR";ALBERT tvrANzO,il; CAROLIM CTAIRE LAURITA MANZO;LATIREN MICHELIE MANZO; 161. Plaintiffs, repeaL reiterate, reallege and each andeveryallegation contained in thoseparagraphsthe complaintmarked designated t|rough 160.,inclusive of and l. with the same forceandeffectasif herein aftersetforthat length. 162, To firy to avert the clear liability and exposure resultingfrom their conduct towards plaintiff JAsoN GoMEz on February z0ll, defendants' 23, lawyersand/ortheir

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representatives prepared Settlement a Agreement Release plaintiff JASONGOMEZ and that wasforced sign. to 163. Paragraph of thatdooument l0 plaintiffJASONGOMEZ to mediare requires and then arbinateany claims arisingout of or relatingto the settlement agreunent, the agreements incorporated thesettlement into agreement thebreach anytermthereof. or of 164. This release was signedby plaintiff JASON GOMEZ undergreatcoercion, duessandphysical emotional and sfress, setfortlrherein as 165. The provisions pamsaph l0 of the Settlement of Agreement Release and mandating dispute resolution mediation arbitationare void anda nullity andplaintiff by and reguests thisCourtadjudicatesassuch. that it 166. Theamount danages of sougbt exceeds jurisdictionof all lowercourts the would otherwise j urisdiction. have 167. Thiscause action of fallswittrintheexceptions Article16of theCivil Practice to (CPLR) theState NewYork. LawandRules of of AS AII{DFORA SEVENTEENTH CAUSEOF ACTION FOR STRIKING PARAGRAPH12OF THE SETTTDMENT AGREEMENTAND GENERALRETEASE BY PLAINTIFFADOLFOARRDOLA TO DEFENDATTTS AS TERESA GIUDICE; GUISEPPE MANZO; CHRISTOPHER THOMAS "JOE" GIUDICE;ALBERTJOSEPH wIANZO;GREGORV JOSEPH BENNETTJR; ATBERT MANzo, III; CARoLINE CTAIRE LAT RITA MANZO; LAURENIVIICHELLEMANZO; SIRENS:, BBAVOMEIIIA. LLC. q+d, 168. Plaintiffs,repeat, reiterate, reallege and eachand everyallegation in contained thoseparagraphs the complaint of marked designated through167.,inclusive and l. with the same forceandeffectasif herein aftersetforthatlength.

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169. To try to avert the clear liability and exposure resultingfrom tlreir conduct towards plaintiffADOLI'OARRDOLAonFebruary 23,20t1,defendants' lawyers and/or their representatives prepareda Settlement Agreementand Releasethat plaintiff ADOLFO ARREOTAwasforcedto sign. 170. Paragraph of thatdocuurent 12 provides plaintiff ADOLX'O that ARREOLAwas authorized execute, bound the Settlement to and by, Ageement thathe wasrepresented and by counsel alsosigned agreement approval ig terms evidence legalassistance who the as of and of andguidance through process. the l7l. However, release signed plaintiffAD0lFo ARREOLAunder this was by great

coercion, duress physical emotional and and sfiess, setforthherein as 172. Further,plaintitr ADOTFO ARREOLA was not represented independent by counsel relating theSettlement to Agreement Release prior communications and and thereto. 173. Therepresentations in paragraph of theSettlement 12 Agreement Release and are a sham. 174, For the reasons forth hereiqparasaph12 of the Settlement set Agrcement and Release void anda nullity andplaintiffrequests thisCowtadjudicatesassuch. is that it 1?5. The amount damages of sought exceeds jwisdictionof all lowercourts ttre that wouldotherwise jurisdiction. have 176. Thiscause action of fallswithintheexceptions Article16of theCivil Practice to LawandRules (CPLR) theState NewYork. of of

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AS AND FORA EIGHTEENTH CAUSE ACTIONFORSTRIKING OF PARAGRAPH OX'TIIE SETTLEMENT 12 AGREEMENT AND GENEML RELEASE BY PLAIMIFF JASONGOMEZASTO DEFENDANTS TERESA GITJI}ICf,; GUISEPPE GIUDICE;ALBERTJoSEpHMANZO; CHRISTOPHER THOMAS "JoE' MANZO;GREGORY JOSEPH BENNETT JR.;ALBERTl\{ANzo, III; CARoLIM CLAIRE LATJRITA MANZO; TAURENMICHELLE MANZO; SIRENS: and.BRAVOMEDIA. LLC. 177, Plaintiffs,repeat, reitorate, reallege and eachand everyallegation contained in thoseparagraphs the complaint of marked designated through175.,inclusive and t. with the same forceandeffectasif herein aftersetforthat length. 178. To try to avert the clear liability and exposure resultingfrom their conduct plaintiff JASON GOMEZ on February towards 23,2011,defendants' lawyers and/ortheir representatives prepared Settlement a Agreement Release plaintitr JASONGOMEZ and that wasforced sign. to 179, Paragraph of that document provides 12 that plaintitr JASON GOMEZ was authorized execute, bound the Settlement to and by, Agreement thathe wasrepresented and by who counsel alsosigned agreement approval its termsandevidence legalassistance the as of of andguidance through process. the 180. However, release signed plaintiff JASON GOMEZ undergreat this was by coercion, duress physical emotional and and stess,assetforthherein l8l. plaintiffJASON Further, GOMEZwasnot reprcsented independent by counsel

relating theSettlement to Agrcement Release priorcommunications and and thereto. 182, Therepresentations in paragraph of the Settlement 12 Agreement Release and are a sham.

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para$aph12 of ttre Settlement and Agreement lS3. For the reasons forth herein, set Release voidanda nullity andplaintiffrequests thisCourtadjudicatesassuch. is it that 184, The amount damages exceeds jurisdictionof all lowercourtsthat the of sought wouldotherwise juisdiction. have 185. Thiscause action of fallswithintheexceptions Article16of theCivil Practice to (CPLR) theState LawandRules of ofNewYork. judgmentagainst WIIEREFORE,the plaintiffsdemand defendants compensatory for damages, punitiveand exemplary and damages suchsumsas a jury would find fair, just, in adequate appropriate. and Dated: NewYork,NewYork 10, June 2011 Yous,etc. Exi. A. Moore, for Attomeys plaintiffs 217Broadway NewYork., NewYork 10007 -4177 Qt2)267 pro A. Esq. Thomas Demehio, (to beadmitted hacvice) Esq. Wliam T. Gibbs, Corboy Demetrio & Street,2ls Floor 33N. Dearbom Chicago, Illinois 60602 (3t2)346-3191

38

SUPREME COTJRT TIM STATE NEWYORK OF OF COUNIYOFNEWYORK X IIIIDEX NO.; ADOLFO ARREOLA, JASON GOMEZ, YOLANDA MARTINEZ, MICAPADUA, coNNIEG'MEZ' Phintiffs, - against TERESA GIUDICE, GUISEPPE GIUDICE, "JOE'' ALBERT JOSEPH MANZO, CHRISTOPHER THOMAS MANZO, GREGORY JOSEPH BENMTT, ALBERT JR, MANZO, III, CAROLINE CLAIRE LAURITA MANZO, LAUREN MICHELLE MANZO, SIRENS MEDIA, LLC, a/lda SIRENS NYPRODCO, and LLC, BRAVO MEDIA, LLC,acorporation,
Defendants.

/11

ATTORNEY

YlN.BlgcAIroN

THOMAS A. MOORE, ESQ.,an attorney duly admitted practice the Cowtsof to in New York State, parfrrer the firm KMMER, DILIOF, LMNGSTON & MOORE, and of attomeys theplaintiffsin thewittrinaction, for hereby affirmsunder penalty perjury: of Thathe hasreadttrewithincomplaint knowsthecontents and thereof, thatthesame and is true to his own knowledge, exceptas to the mattersthereinstatedto be allegedupon information belief,andthatasto those and matters believes to betue. he it Thatthe sources his information knowledge investigations records the of and are and in file. Thatthe reason verification madeby affirmantandnot by the plaintiffsis that the this is plaintiffsarenotwithintheCounty where attomey hisoffrce. the has Dated: NewYork,NewYork June 10,2011

IndexNo.

Year 201I

SUPREME COURTOF TIIE STATEOF NEW YORK COUNTY NEWYORK OF ADOLFO ARREOLA, JASON GOMHZ, YOLANDA MARTINEZ. MICAPADUA. CONNIE GOMEZ, Plointffis), - against I'ERESA GIUDICE. GUISEPPE GIUDICE, "JOE'' ALBERT JOSEPH MANZO, CHRISTOPHER ]'I{OMAS MANZO, GREGORY JOSEPH BENNETT, AI,I]I]Rl'MANZO, JR., ilT. CAROLINE CLAIRE LAIJIII'|AMANZO, LAUREN MICHELLE MANZO, SIRENS MEDIA,LLC, a/</a SIRENS NYPRODCO, and LLC, BRAVO MEDIA.LLC,a corporation, Defendant(s),

,kae%

SUMMONS ANDVERIFII'ID COMPI,AINT KRAMER,DILLOF,LIVTNGSTON MOORE, & ESQS.

Attorncys Plaintlf(s) for )fice andPost OficeAddress, Telephone

217Broadway NewYork, NewYork10007 (2r2)267-4177

ro: All Parties