Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 1 of 17 Page ID #:1 1 ALLISON S. HART (BAR NO. 190409) 2
[email protected] KELSEY J. LEEKER (BAR NO. 313437) 3
[email protected] 4 LAVELY & SINGER PROFESSIONAL CORPORATION 5 2049 Century Park East, Suite 2400 6 Los Angeles, California 90067-2906 Telephone: (310) 556-3501 7 Facsimile: (310) 556-3615 8 Attorneys for Plaintiff TYLER ARMES 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 TYLER ARMES, CASE NO. 2:20-CV-3212 12 13 Plaintiff, COMPLAINT FOR: 14 v. 1. DECLARATORY JUDGMENT 15 AUSTIN RICHARD POST, publicly 2. ACCOUNTING 3. CONSTRUCTIVE TRUST 16 known as POST MALONE, an individual; ADAM KING FEENEY 17 publicly known as FRANK DUKES, [DEMAND FOR JURY TRIAL] 18 an individual; UNIVERSAL MUSIC GROUP, INC., a Delaware 19 corporation; DOES 1 through 10, 20 inclusive, 21 Defendants. 22 23 Plaintiff Tyler Armes alleges as follows: 24 INTRODUCTION 25 1. This case arises from Post Malone’s (“Post”) and his producer Frank 26 Dukes’ (“Dukes”) bad faith refusal to accord Tyler Armes (“Armes”) the credit and 27 share of the profits he is due as a co-writer of the song Circles, which is perhaps 28 1 K:\6820-2\PLE\COMPLAINT COMPLAINT Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 2 of 17 Page ID #:2 1 Post’s biggest hit to date and was named by Billboard as among the top 10 best 2 songs of 2019. Circles was released on August 30, 2019, to much critical praise and 3 it debuted at Number 7 on the Billboard Hot 100 Chart.