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 , an individual; ADAM KING FEENEY 17 publicly known as FRANK DUKES, [DEMAND FOR JURY TRIAL] 18 an individual; , 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 B 10

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. It quickly shot to Number 4 1, where it spent three (3) weeks, and to this day it remains in the Billboard Hot 5 100 5 . 6 2. Armes is a professional , musician and producer. He is also 7 the bandleader, writer and producer for the bands , which was 8 signed to by Sylvia Rhone in 2009, and Honors. With Armes at the helm, 9 Down With Webster has sold multiple platinum and over One Million 10 (1,000,000) singles, and it has been nominated for a number of Juno Awards, 11 MuchMusic Video Awards and Canadian Radio Music Awards. Armes wrote and 12 (5) D (5) Can singles including, 13 Rich Girl$, Your Man, , One in a Million and Chills. Armes, with Down 14 With Webster, has performed sold- , 15 well as performing at the Juno Awards, MuchMusic Video Awards and the Grey 16 Cup, the championship game of the Canadian Football League. Not only has Armes 17 been the leader of one commercially successful band, but he also created a second 18 project called Honors that has also been commercially successful. 19 Over was the Number 1 Global Viral Track on in January 2017, and it 20 charted on the US Alternative Radio charts. Honors was courted by multiple major 21 record labels and, after receiving multiple offers, it signed with PRMD, the label 22 helmed by Ash Pournouri, who is best known for managing the artist Avicci. In 23 addition, Armes individually, has a music publishing deal with Warner Chappell 24 Music, and A , 25 Baseball, TBS, Fox and The Voice on NBC. Armes has also collaborated with 26 some of the top writers and producers in the music industry, including , 27 Justin Tranter, Jesse Saint John and . Armes also co-wrote and produced a 28 B 1 My Turn, released on February 2 K:\6820-2\PLE\COMPLAINT COMPLAINT

Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 3 of 17 Page ID #:3

1 28, 2020, and he co- $

2 .

3 3. A 8, 2018, 4 manager, Dre London (D), that Armes and Post should collaborate to write 5 music together, Dre invited Armes to join Post D D 6 together. When Post found out that Armes was a talented multi-instrumental 7 , , a ! Armes spent hours in the 8 studio jamming with Post and Dukes and ultimately co-writing the song Circles. 9 4. Although Post has freely admitted that Armes co-wrote Circles with 10 D A 2018 D , D 11 have refused to credit Armes as a co-writer and have refused to pay Armes a fair 12 share of the monies derived from the exploitation of Circles. Despite repeated 13 efforts by Armes to amicably resolve this matter, Post and Dukes have steadfastly 14 refused to give Armes the credit and share of the profits he is due. 15 16 JURISDICTION AND VENUE 17 5. 18 United States, as amended (17 U.S.C. § 101, et seq.) The Court has subject matter 19 jurisdiction over this claim pursuant to 28 U.S.C. §§ 1331, 1332 and 1338, and 20 supplemental jurisdiction over the remaining claims pursuant to 28 U.S.C. § 1367. 21 6. Venue is proper in this district 28 U.SC. § 1391(b)(2) because 22 Defendant has committed acts directed at this judicial district, where Plaintiff 23 resides. 24 25 THE PARTIES 26 7. A ( A) a songwriter, 27 producer and composer, and at all times relevant hereto was, an individual residing 28 in the County of Los Angeles, California. 3 K:\6820-2\PLE\COMPLAINT COMPLAINT

Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 4 of 17 Page ID #:4

1 8. Plaintiff is informed and believes and based thereon alleges that

2 D A , (), ,

3 all times relevant hereto was, an individual residing and doing business in the 4 County of Los Angeles, State of California. 5 9. Plaintiff is informed and believes and based thereon alleges that 6 D A F, F D (D) , 7 all times relevant hereto was, an individual doing business in the County of Los 8 Angeles, State of California. 9 10. Plaintiff is informed and believes and based thereon alleges that 10 D , . () , 11 division, the distributor of the song entitled Circles, and at all times relevant hereto 12 was a Delaware corporation with its principal place of business in the County of Los 13 Angeles, State of California. 14 11. The true names and capacities of the Defendants sued herein as Does 1 15 through 10, inclusive, are currently unknown to Plaintiff, who therefore sues such 16 Defendants by fictitious names. Plaintiff will amend this Complaint to allege the 17 true identities of such Doe Defendants when their identities are discovered. Plaintiff 18 is informed and believes, and thereon alleges, that each such fictitiously named Doe 19 Defendant is responsible in some manner for the events alleged in this Complaint 20 21 conduct of such Doe Defendants, and each of them, and that Defendants in 22 committing the acts and omissions alleged herein acted as agents and servants of one 23 another, acted within the scope of their authority as agents and servants of each 24 other, and/or approved and ratified the acts and/or omissions of each other. 25 26 ALLEGATIONS COMMON TO ALL CLAIMS 27 12. D (D) usic manager whose best known client is 28 . A D 2015. A A hit 4 K:\6820-2\PLE\COMPLAINT COMPLAINT

Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 5 of 17 Page ID #:5

1 single Over was released and became a viral hit in 2017, Dre began actively courting 2 Armes and Honors to sign with him. On a number of occasions, Dre has also 3 encouraged Armes to get into the studio with Post to collaborate. 4 13. In early August 2018, at Dre’s invitation, Armes attended a private 5 concert at which Post was performing in , Canada. The following evening, 6 Dre again invited Armes to get into the studio with Post to write music together. 7 14. The following evening, Armes, Dre, Post and Dukes went to see a 8 band that Post was a fan of play at a club in Toronto. After the show, Dre again 9 invited Armes to go to Duke’s Toronto studio with Post and Dukes to write music 10 together. Dre told Post that Armes is “an amazing musician” and that he should 11 check out Armes’ band. When Post learned that Armes was a legitimate musician 12 and composer and proficient with multiple instruments, he was excited to jam with 13 Armes, and write music together. 14 15. From approximately 2:00 a.m. on August 8, 2018 until 9:00 a.m. that 15 morning, Armes, Post and Dukes worked together in the studio, with Armes on bass, 16 Post on drums and Dukes playing guitar and keyboards. That collaboration resulted 17 in the song Circles (the “Song”), Post’s fourth number one song on the US Billboard 18 Hot 100, and his first as the only credited artist on the track. 19 16. At Dukes’ studio on August 8, 2018, Armes and Dukes co-wrote the 20 chords for the Song on the keyboard, and Armes co-wrote and had significant input 21 in the bassline for the Song. Armes also had input on the guitar parts in the Song, 22 including co-writing the guitar melody which is played in the introduction to the 23 Song and which repeats throughout the Song. 24 17. A recording engineer at the studio observed Armes working alongside 25 Post and Dukes to create the Song, and set up Dukes’ equipment and Dukes 26 recorded the music composed by Armes, Post and Dukes that night with Dukes 27 playing the bass parts co-written by Armes and Post playing guitar parts co-written 28 by Armes. At the end of the session that morning, Dukes played back the recording 5 K:\6820-2\PLE\COMPLAINT COMPLAINT Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 6 of 17 Page ID #:6

1 for Armes and Post, and the three of them were thrilled with the results of their 2 collaboration. Dukes exclaimed, “It’s so fucking good! It’s a whole new sound 3 man. Post said, “It’s super special,” and “that’s gonna be the next … we’re just 4 gonna, for the next we’re just gonna use a fuck load of reverb,” and Dukes 5 said, “this kind of track would be insane to play live.” 6 18. Although the lyrics had not yet been completed, other than the main 7 lyric and title of the Song, i.e., “circles”, all instrumentation and vocal melodies in 8 the song recorded at Dukes’ studio on August 8, 2018 are note for note rhythmically 9 and melodically identical to the Song and have the same main lyric, title and 10 concept, including without limitation the guitar introduction co-written by Armes, 11 and the bassline and chords co-written by Armes. Everything but the bridge vocal 12 melody was conceived that night. 13 19. The Song is also dramatically different from other music previously 14 released by Post. Significantly, although Post is well known as a hip-hop artist, 15 typically performing lyrics over a rap track, the Song is the first major release by 16 Post not to appear on any hip-hop charts. As Chris Molanphy observed about the 17 Song in a December 5, 2019 article for Slate entitled, “Post Malone Might Finally 18 Be Getting His Wish to Escape Hip Hop,” unlike Post’s prior music, “the melody is 19 sparkling, with prominent guitar arpeggios and a wistful sigh of a chorus that, 20 dare I say it, soars. Post Malone has never been about the soar.” Indeed, the style 21 and sound of the Song is more similar to music created by Armes for his bands 22 Down With Webster and Honors than it is to any of Post’s prior music. 23 20. On August 5, 2019, Dre posted a snippet of the Song on Instagram, 24 and Post premiered the Song live that night during his Bud Light Dive Bar Tour 25 show in . The Song was released by Defendant UMG through its 26 label on August 30, 2019. The Song debuted at Number 7, 27 reached Number 1 on the US Billboard Hot 100 for the week of November 30, 2019, 28 where it remained for three (3) non-consecutive weeks, and to this day it remains 6 K:\6820-2\PLE\COMPLAINT COMPLAINT Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 7 of 17 Page ID #:7

1 one of the top 5 most popular songs on the Billboard charts. The Song received th 2 critical praise, with Billboard naming it the seventh (7 ) best song of 2019, and

3 , 4 , guitars, swirling 5 . 6 21. When Dre posted the Song on Instagram on August 5, 2019, Armes 7 immediately reached out to him and sent him the following text message: 8 Dre, I need you to ask Post about this please. 9 Post asked me to write with them and jam and we did for well over an hour 10 in the live recording room coming up with the jam that lead into the 11 recording of circles. 12 I was there until long after the sun came up with them in the main room 13 working on the song and playing different instruments and contributing to 14 ideas from start to finish. 15 Specifically the bass and guitar parts, post ended up tracking them after I 16 was playing. I was beside him giving input on both of them. I was not just 17 someone hanging , I a /c 18 two other writer/producers working on a song. 19 I a a a I . I b 100 20 sessions with Lou while he was working at EF with different artists, I know 21 when I am just hanging out. This was much different. 22 I was part of the writing process. The entire song (minus the lyrics other 23 a cc) a a a 3 24 together, working together. 25 Trying to just be fair here. Not asking for much. Would just like credit and 26 a b. Pa a . I a C aa 27 a aa. Ta b, c . 28 7 K:\6820-2\PLE\COMPLAINT COMPLAINT

Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 8 of 17 Page ID #:8

1 22. On August 9, 2019, Dre responded to Armes, Just showed Posty the

2 message [¶] He said he remembers [¶] U played a tune on the bass then he played

3 more of it after. Thus Post acknowledged that Armes co-wrote the Song with him 4 D . In p, A contributions to the bass line in 5 the Song. Notwithstanding the foregoing, to date, Defendants have refused to credit 6 Armes as a co-writer of the Song and have refused to pay him any share of the 7 publishing royalties for the Song. 8 23. The credited writers on the song are Post, Dukes, Billy Walsh, who 9 Armes is informed wrote the lyrics, , a producer with whom Post and 10 Dukes frequently collaborate and who Armes is informed recorded the vocal track 11 for the Song, and Kaan Gunesberk, another producer who also frequently 12 collaborates with Dukes. Other than Post and Dukes, none of the foregoing credited 13 co- A, D D 14 when they composed the guitar, bass and melody of Song on August 8, 2018. 15 24. After Dre informed Armes that Post remembered and acknowledged 16 that Armes co-wrote the Song, Post initially offered to give Armes a five percent 17 (5%) share of the publishing royalties. In response, Armes attempted to negotiate to 18 receive a larger percentage of the royalties that more fairly reflected his significant 19 contributions to the Song, and one of his representatives requested that he be 20 credited as a co-writer and co-producer of the Song while they attempted to reach an 21 agreement on A share of the publishing royalties. Defendants refused. Instead, 22 Austin Rosen, who manages both Post and Dukes, threatened A , C 23 , A so-called 24 (5%) of the publishing, then he would get nothing no credit and no publishing 25 royalties. Thus, Defendants have retaliated and attempted to punish Armes for not 26 accepting their low-ball offer on the publishing royalties by refusing to credit Armes 27 as a co-writer and co-producer of the Song, notwithstanding the fact that Post has 28 acknowledged that Armes co-wrote the Song. 8 K:\6820-2\PLE\COMPLAINT COMPLAINT

Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 9 of 17 Page ID #:9

1 25. On November 15, 2019, Plaintiff filed a copyright registration for the

2 Song, identifying Armes and Defendants Post and Dukes as co-writers of the music

3 (composition) and sound recording of the Song. A true and correct copy of said 4 copyright registration is attached hereto as Exhibit A. 5 26. D A -writer and co-producer of 6 A , 7 host of opportunities that otherwise would have been available had Armes been 8 properly credited as a co-writer and co-producer of the Song when it was initially 9 released. Composers credited with writing hit songs are invited to work with the top 10 artists in the music industry, among other potentially lucrative opportunities. 11 27. and composers work their entire lives to create a 12 commercially successful and critically acclaimed song like the Song. As a direct 13 D A -writing credit he 14 ad , A 15 credit to date, Defendants have prevented Armes from capitalizing on the success of 16 the Song in order to further his career in the music industry. 17 18 FIRST CLAIM FOR RELIEF 19 (For Declaratory Judgment against all Defendants) 20 28. Plaintiff repeats, realleges and incorporates by reference each and 21 every allegation contained in Paragraphs 1 through 27, inclusive, of this Complaint 22 as if fully set forth herein. 23 29. An actual and present controversy now exists between Plaintiff and 24 D -writer and co-producer of the Song. 25 D -writer and co- 26 producer of the sound recording and composition of the Song, which entitles 27 Plaintiff to writer credit and a share of the monies generated from the exploitation of 28 the Song. 9 K:\6820-2\PLE\COMPLAINT COMPLAINT

Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 10 of 17 Page ID #:10

1 30. Plaintiff contends that he is a co-writer and co-producer with

2 Defendants Post and Dukes on the sound recording and the composition of the Song.

3 Plaintiff and Defendants Post and Dukes each jointly contributed separate and 4 distinct copyrightable chord progressions, melody, and rhythm to the Song. They 5 each possessed independent creative control over their respective contributions. 6 31. Plaintiff and Defendants Post and Dukes each manifested an intent to 7 be co-writers of the Song, and worked together jointly to create the Song. Plaintiff, 8 Post and Dukes intended that their separate contributions be merged into inseparable 9 or interdependent parts of a unitary composition. 10 32. Plaintiff contributed significantly to the Song, including composing the 11 guitar introduction at the beginning and which repeats throughout the Song, as well 12 as making significant contributions to the bass line of the Song and the chords in the 13 Song. 14 33. An actual and present controver 15 respective rights to the Song. Pursuant to the Federal Declaratory Judgment Act, 28 16 U.S.C. § 2201, Plaintiff is entitled to a declaration of rights as follows: (a) Plaintiff 17 is a co-writer and co-producer of the sound recording entitled Circles; (b) Plaintiff is 18 a co-writer of the composition entitled Circles; (c) Plaintiff is entitled to a co-writer 19 and co-producer credit on the copyright to the Song and on subsequently released 20 versions of the Song; and (d) Plaintiff is entitled to prospective and retroactive 21 royalties and other money owed with respect to his interest in the Song. 22 23 SECOND CLAIM FOR RELIEF 24 (For Accounting against all Defendants) 25 34. Plaintiff repeats, realleges and incorporates by reference each and 26 every allegation contained in Paragraphs 1 through 27, inclusive, of this Complaint 27 as if fully set forth herein. 28 10 K:\6820-2\PLE\COMPLAINT COMPLAINT

Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 11 of 17 Page ID #:11

1 35. Plaintiff, as joint author and co-owner of the copyright of the sound

2 recording and composition of the Song is entitled to his pro rata share of the profits

3 that Defendants have enjoyed from the exploitation of the Song. 4 36. By commercially exploiting the Song without accounting to Plaintiff 5 for profits, Defendants have wrongfully deprived Plaintiff of his rightful share of 6 income therefrom. 7 37. Defendants are in sole control of the books and records needed to 8 ascertain the amounts due to Plaintiff pursuant to their special relationship as joint 9 authors and co-owners of the composition of the Song. Plaintiff has no means by 10 which he can assemble the information necessary to calculate what is owed to him 11 by Defendants. 12 38. Plaintiff is entitled to an order of this Court directing Defendants to 13 render a complete and honest accounting of all revenues derived from the 14 exploitation of the Song and all sums due to Plaintiff and to pay Plaintiff the sums 15 shown due by such accounting. 16 17 THIRD CLAIM FOR RELIEF 18 (For Constructive Trust against all Defendants) 19 39. Plaintiff repeats, realleges and incorporates by reference each and 20 every allegation contained in Paragraphs 1 through 27, inclusive, of this Complaint 21 as if fully set forth herein. 22 40. By virtue of the foregoing, any interest that Plaintiff has in the Song, 23 and any and all profits received by Defendants Post and Dukes from the commercial 24 exploitation of the Song, are the property of Plaintiff, Post and Dukes in equal 25 shares. 26 41. Post and Dukes have wrongfully deprived Plaintiff of his share of the 27 profits that they have enjoyed from the commercial exploitation of the Song. 28 11 K:\6820-2\PLE\COMPLAINT COMPLAINT

Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 12 of 17 Page ID #:12

1 42. B D , D

2 from the exploitation of the Song as constructive trustees for the benefit of Plaintiff

3 and Defendants. 4 43. Plaintiff is entitled to immediate possession of his pro rata share of the 5 profits held by Defendants as constructive trustees. 6 7 PRAYER FOR RELIEF 8 WHEREFORE, Plaintiff prays for judgment against Defendants as follows: 9 1. That the Court declare that as follows: (a) Plaintiff is a joint author 10 and has an ownership interest in the sound recording entitled Circles; (b) Plaintiff is 11 a joint author of the composition entitled Circles; (c) Plaintiff is entitled to a co- 12 writer and co-producer credit on the copyright to the sound recording and 13 composition entitled Circles, and on subsequently released versions of Circles; and 14 (d) Plaintiff is entitled to prospective and retroactive royalties and other money 15 owed with respect to his respective interest in the sound recording and composition 16 entitled Circles, in a percentage to be proven at trial; 17 2. That the Court order an accounting of all revenues derived from the 18 exploitation of the Song by Defendants; 19 3. That the Court impose a constructive trust over the proceeds from the 20 exploitation of the Song pending the final disposition of this action; 21 4. 22 pursuant to Section 505 of the U.S. Copyright Act (17 U.S.C. § 505); and 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 / / / 12 K:\6820-2\PLE\COMPLAINT COMPLAINT

Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 13 of 17 Page ID #:13

1 5. For such other and further relief as the Court deems to be just and

2 proper.

3 DATE: April 7, 2020 ALLISON S. HART 4 KELSEY J. LEEKER 5 LAVELY & SINGER PROFESSIONAL CORPORATION 6

7

8 By: ______9 ALLISON S. HART Attorneys for Plaintiff TYLER ARMES 10 11 12 13 14 15

16 17 18 19 20 21 22

23 24 25 26 27 28 13 K:\6820-2\PLE\COMPLAINT COMPLAINT

Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 14 of 17 Page ID #:14

1 DEMAND FOR JURY TRIAL

2 Plaintiff Tyler Armes hereby demands a trial by jury.

3 DATE: April 7, 2020 ALLISON S. HART 4 KELSEY J. LEEKER 5 LAVELY & SINGER PROFESSIONAL CORPORATION 6

7

8 By: ______9 ALLISON S. HART Attorneys for Plaintiff TYLER ARMES 10 11 12 13 14 15

16 17 18 19 20 21 22

23 24 25 26 27 28 14 K:\6820-2\PLE\COMPLAINT COMPLAINT

Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 15 of 17 Page ID #:15

EXHIBIT A Case_e• 2:20-cv-03212 Document 1 Filed 04/07/20 Page 16 of 17 Page ID #:16 - Certificate of Registration- s

. sTAT4. 1 s. This Certificate issued under the seal of the Copyright Office in accordance with title 17, United States Code., 1') attests that registration has been made for the wor ). identified below. The information on this certificate hai' z been made a part of the Copyright Office records. -L; Registrati 1,1•• • go SR 860-, lI • 147 0 .5) Effective Date- C' November 15, 201 Acting United States Register o opyrig is and Director Registration Deci 0 January 10 202Q.,1

-o o)

Title

Title of Work: Circles

Completion/Publication

Year of Completion: 201 , Date of 1st Publication: August 30, 2019 Nation of 1st Publication: United States - -' International Standard Number: ISRC USUM71915699

Author

C ) ; 4 (4*,- • Author: Tyler Armes _et Author Created: sound recording, music and production-, Citizen of: Canada

r- Domiciled in: Canada Year Born: 1985 •

r- ‘ opyright Claimant

J Copyright Claimant: Tyler Armes - 4-, - - 43 Hambly Ave, Toronto, ON, M4E 2R5, Canada' r. "C: 6, (, . - a Page 1 of 2 I O

_ li o .01 r, 1 * l lect(14114114 6114444.44.40.4 4-0.141.01141,- (44010 00#19- -$. 64.; Case 2:20-cv-03212 Document 1 Filed 04/07/20 Page 17 of 17 Page ID #:17 • e AN1k..rsVN)'6001.0.°0:). .e.%).5k16:0C.e.te.6ettedeC4.0.0:). .o..e.,43/%0*#*-AcSet44 1C-44k4 -4 044.o.)frik,0. ,•4'1 4040004000040000110110000100140400000001004* reif.p.)444citi citSPArecePAPAWY410.64,00/eop.o"0000)406s)orwo)tocook,041646A- rtjtikeVetl**40w 6 0ew 64004-100644,451 . 00.00Kco"otivsccor;14/ 4eftoe-g-o(Apecopeopeoppea-Noorkveocopoppeo. €• e'ece'oc.'"c\gAs--c4-644 0rs-%c-Noclodlottqf*Vteket co cee-eofrofo ,ro,,o .01-64- <.0)0 14.0,5)-90--Ockirkookoofted-W- of* .(*) Alo 4rof,'", (0),„,co).634-flo.) 15koecefec, f., ,,;) r.,, , '4).,...00 Cto)49K,44.4"0" 64391-%Voec*al14/ 6.04,.00rtoorkofee,.)0w61004%-.494414/44k40*.#44*-0*--ec-44rok )lowwwt 0*.etcSioo:?. : 5-c-vo, A-9440,,01;c4rA V.,,,,1 c:0010.14A.k.004.4AACco.1,,Ccoa"Cd-00/40,4Aki-$4- ,04.4C 0!)..4004..,: .e.,Ap .hglt-i4w4.4:= 1,..„....„.._._._...... _._....„,...... „...... _,.._.vowt,osork",040ftewea,m,040,„fte.tv.pfcmget,co4r.a. o. we...,,,lewp,A ...,...... ,... ci.,,,,,,,,.g". 04,41, .0,0:4 Se , i!-.,--airscw ..,--) '47 w14XiMPTIVPOTOPInVirtia4.'0'6314707.95r61Vreit leceSliticitRifp (-)M.E4440C-409 441M.€4e.Cev r o **4 9.004 9.C6,0, Name: Tyler Armes --v?'(.44.10041064.1.0641064-00.):01S4140.1S4A0,:e l*,4111.5444C.,4,. (546 . Email: tylerarrnes @ grn ail . ACcielitr41 rWa 0(0.,k1Ve."04:100):),?r%V .E00.- 9DACG-O fkvecv.eCcea%sa::104"0,),A 04. ), V ite0Sk#4 9 4 .44 ° %4 1 40a0.4 aCe04360.-0. f)00-0aC6011%Va a c 4 4% ONi*,61,40. ,)_ Telephone: (310)895-3121 .)1%!..)14e601,et.0141 W0041"0:0?:10614.1"4,9'. btitikt o tp x1-0 0p - Alt. Telephone: (646M6-5574 AktpV41•40 604e," .40 6%:10,e6 13, PA.:%\-YJAVIelltt-ISIIII ?AIN ,; "e4, " RA Ace-restv...* eetv.. w , es „...,, ...elk.,..dv,..,esogor*Orse4oeseg ..6,, ;..,,,,, o:g:r Mi4.1ctOrk '‘ 441,11tOr A'.‘ Mie.1ccgi .'4'o s Itto gorkOrsell .1.Ve,t ,..),.% : %ci%r .9.* Po„.(crA. PogdrAstreeti. . Po,. . ..t.,. . pe.. -v- (--\` - ' 7 X KIMPFCINCVFPF CVFFVFVF1 94% 9-4 .-,Na me: Tyler Armes,-f6, 4 0 41140044.060g?) ,6401-444#4,N1 -40.1c. C.4.% ."04.0 4 , 4%*le6 .9 * -4-pe_619.64.10)151c%4 6-0 cjc• ow• e)e edv. ii, ew kr. 6 A"P404".co.:0.0.6€050`,; Date: November 15 2019\;:4% 4 1( 4 .1r 4 9* C')C60 (66 9)f°46:cO t*tVg ea 9jclkt4 440 17)-CoklOCAtlaato.ct:;43 ,--s-,'-') -*;- , . -•' '.--',42east;3 AoSfiatc*io'Moittztttw24S*S;, - *N0104565lits4. marverIm.040eito40.040)0mtitImeelmeoA40. 61. .N,.)1.:3 % 1.:,) s.N.0.Tlm&rimer*OPPOW,S5POPPCS06s.00kpvt,)5y61060.60e4,10zetw5MoetetA1 70: 0"3cktot0Zg 44%0. t.40r.4 0.)"106%.106%. ."106Meetat06%. 1401,.,106%.43 ,2"We V3d 006g4",406%. ." L'Oe. 0,04: b 'VeNtitoteito&4C-'SV• VV4-4 3*%*%*640C-6a4PPP0e*6-#66:* €4C#F 4 4:* (:-COACCOPF"PrC0VNIVfkteccfet.otkeSe*4e0A5%*(00""A"Pet eeetV 0i,01%,41,AciPioi,oleioie&iroZoloVelCAlkOliofrAcp41406#64V-6;33000 064650640- e -e-AP*40,469**OeoPt-.0 40*%1 0Poo"OccoNccol'eersev l: cceeP"4006$40%)-Wro.- 40%461- €-weleew.00-0140L6401.6401,664,4sikozeikecAe511,640C44l0e&44.NIVotot000totoeototot0*se&motoosetNetcioo0rt,.401#40%,5VAeiteccfacketeketeceSoc.03.").40%.is ork34:setN,400e*".#,. -0KGOPLP,OcconCoo- 010vottotot6;etoome6-0Nevi*V)KVez*:.50K9640toe6.4eNet#:#6coorA001- 4.05)0#0-4-9)e-o9viocevSccoPetcoPFAVetviN%, 4-45)045*-.4k4eceslk-41 -e 0 tqq" 0&1043,4-5f40",-)frAtSAlkieLoirk,-kle-oofWoorot3'4(06406404)-oorke-'0 eotKoAkt'Asct41.06- vois40P6.-oPP.0%-liNk4o)*Viktg--4,- fli- ,0-0635Pse4 vo.0Fsevoiloo",10641064,%19649*ccaor*PAAAAPPecevv"16y6lemeolve,3-.5k9e,oelece4- t tte- t"let,ok :09.0(ce40%.1300,6 4:.ei.)*"4 6. 34410.t.A46..0400(s4). 0060.A".."06,14410.10664. .00-10.0.e. &OR- coAci4c,). C AftokAPeOr"PeteetPecer"PeotSiMteroloPtP:AiVtolroU'oebiletoi(0 $eceefticcAroVtO".00000000000410.. , 10;0001000g44004:"3).14,06%leieetoop. Aero).A"),10444',k4€10104001054:11%6V400€-,6.:;9 6€013096%..0 co'c %V. 40,-erlare'4.-40,4-4*(croPg-0(44-0.e4-Oroer\01rsce-OrccW-ove040("Orso,"%le- oc oto440rto,1roo"..q03);-$00.),406100,1k0);Iratv4?..i6koqwe.)0wfmrpw.00fiko.4"04010.?"-WS406406440/C4)514:WttrokeV**VitifiteitketetlOtetStviSt.04., ** e.c.%*- '44* c4* (% *: (cAP4S e #P 4 :0N 4 41 fg roA4 4 - Or scear*oA4oPrvors o oN cego - * 64 0 eA 0 1 04 6544 0 iteet# 11fel o t Re o #C 64Vo ''' 4 4416 4-V 0 4 15VeCoometioN !cft6V4. o.4,..co,,-0ctal4§241sr%%),-,f ,ifkz,o,-,e6401044‘.to,,e6cv),,„44144f" ;r3,o14444440e,Aet,,,,,,-)"...,-,.4;444r,o 64401:Po.,N4wRo"..4,",,,...0414:1 0e00e..",.d,".0E440P;p.,41 -1; 4:470*V1+14,014434.4,734,444444€444,-)40N+84444*-3 PetecAVK,c\A"Peoctolat"SwirotolfOR:340,4034,404+03444,14-000-3e (0 refolote3V74"WP46- 0P444444F0,64eCoecfec.t4k4"00,#444%-oitAtAK4,400 -oPEAtAccvlevAiWc6040-34t63434: 6640Aroe?,,k._0104144613016W0 630C 04900Wor-V."0e. cetic51449.. 6' t-a3r4P*Ve- oswes-rOkoto5roopfptoo;A.,,0,-.740,,,eZoote0NOtolokitstWoNONA.44014151M0k4orooNfkoegwo,4Koo-40c000vee4pe:4i.,. ViooVpPFo*c- iii-oWoeise0tvietToet-c#PsV)Psccees%AsVr%loo'-eoWVoVocceoA"eoPee"Nisa'6-#60-0960400 4-etf.:#0,e4totect#045)40041-040,t443)69 Cel 004 roci,40toie&9(00"1":4104.,4:1%4064" 000~s .VjAceiktoPPl -V-00%*0-60060oioavocce"oroceectaloceedaletemccolroceoAk%eokoforoe40640eJ ,64#0 #.#041%4,44-0610 04)V-6-4V6v00.00,1*-00)044#- 010031kfect400400A0*,494.4%-5)1VA 4P4oNsctoPP‘Oiroo*iiolvAiW00%11 4-.0 4 064-Aso:406461WWe0400k4citce""~6 4- 064-064e. ite#6.0)1064#1*.eNfotooltootkoettecbtkelededec444*%*-Vesoave"1" 0" 1" 1"PeoeceoPdaMaletio9005*-0000 4oirkse5e1064. 6, -. Vlro‘O40-410101;1i1%406460646 5Wc;; oe-45350(tAtt, .4rosee.owofrocAtoaceoft40%-oRevegeoftt,40Npork)frooe49900%etrowa,:.40A040,04re,,tree .,,,.0rce.).,.o pve *o.0r0o,o61, vo,.rsv*co ife e3,4rNcowN64, t 4 e-OPs%veccioe"*"VAocVoccvoroo-oA"Sceeee0tAt"t"ic"Cte.e.5).- .e - 'roito'VcteLcoet.SVttofVecfeccSf'kctoVttktet4e*-slk4"WccWoWafk4e*-:irew,ssite eicv". ,ioeAiko"ti"v" to"" >:40coo e o0e0t o tof"se". 0 . ,,•:e;, 2 r4 0 glicec* t ., .' o,74 Po 0 4P110) 10 1: 0P44 St] LtCht, 40-Jit, 14,2 4,34 LW; Costo:Ifit . ).0 1 .eo. 1 .IV .• . 1i .43-4. lli' P6N14. .5V 14 16)6 114 51YeteV 6V1 64k 6s14 1 0000 5.#0 6. 4 5W 3)04 :V d4k44 9 4 .0* . ' (' '"6' '0630-filta•rt sttekjiegleOp rkoti0:6,43 0,440NO443 0,40"6NN.,431,6, Ort64. eV rs %Pe :) rs. :) ,es0.P‘:), re'er*vdecc4)46r. J . )44:MoAtilac-eve • &Pro-Zi...4 • 9 'T t21 4 0k ,ffco.6 4 .r41,t.`4.6: 4 ro..5 l e45).Cti# IgoN ffiaI V#4f1 .rotica34 .efo.e6:1 .e,4 .e.c4, ec:i..). ,ose..4 00 . 0, 04,-,. 4 1 446 netV) 0 . .1. - , -,-- Voific‘d f- ficYiko.(;e-alkeYe 010cYNLVI*02c$420/31001. *, .0* ' icee.V.0.0. 14pv" e. ,,t)e. #). .0.09. o.do 0•052(41.-el-v zo1 e -40.711- M 34%.6-k 14 1 1 (144 )41414* 4 6't,. -V".• litb"•. ( 4 '