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1 FILED: NEW YORK COUNTY CLERK 12/16/2013 INDEX NO /2013 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 12/16/2013 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK )( MICHELLE L. MORILLO, D ORIGINAL Plaintiff, against- BEAR GALLERY INC. d/b/a HUBERT GALLERY, GREGORY L. HUBERT, in his corporate capacity as CEO of Bear Gallery Inc. and in his individual capacity, and JULIE HUBERT, in her corporate capacity as President of Bear Gallery Inc. and in her individual capacity, SUMMONS Index No Date Purchased: ---- Assigned Judge_: Defendants )( TO: Bear Gallery, Inc. d/b/a Hubert Gallery 1046 Madison A venue NY, NY, YOU ARE SUMMONED to answer the Complaint in this action and to serve a copy of your Answer, or if the Complaint is not served with this Summons, to serve a Notice of Appearance, on Plaintiff's attorney within twenty (20) days after the service of this Summons, exclusive of the day of service (or within thirty [30] days after the service is complete if this Summons is not personally delivered to you within the State of New York), and in case of your failure to appear or to answer, judgment will be taken against you by default for the relief demanded in the Complaint. Date: December 6, 2013 Cornwall, New York 1

2 LAW OFFICES F JIMMY M. SANTOS, PLLC 2

3 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK )( MICHELLE L. MORILLO, Plaintiff, against- BEAR GALLERY INC. d/b/a HUBERT GALLERY, GREGORY L. HUBERT, in his corporate capacity as CEO of Bear Gallery Inc. and in his individual capacity, and JULIE HUBERT, in her corporate capacity as President of Bear Gallery Inc. and in her individual capacity, VERIFIED COMPLAINT Index No Assigned Judge: Defendants )( Plaintiff, through her counsel, Jimmy M. Santos, Esq., of the Law Offices of Jimmy M. Santos, PLLC, brings her Verified Complaint and alleges against defendants as follows: I. THE PARTIES & JURISDICTION 1. Plaintiff Michelle L. Morillo ("plaintiff' or "Morillo"), resides at 1157 Third Avenue, County ofnew York, State ofnew York. 2. At all relevant times, plaintiff was employed by defendants Bear Gallery Inc. d/b/a/ Hubert Gallery (or, the "Gallery"), Gregory L. Hubert and Julie Hubert (collectively, the "Huberts"). Upon information and belief, at all relevant times, Gregory L. Hubert ("G. Hubert") served and continues to serve as CEO of the Gallery, and Julie Hubert ("J. Hubert") served and continues to serve as President of the Gallery, and are the sole owners/ shareholders the Gallery. 1

4 3. At all relevant times, plaintiff was employed by defendants as a "commission salesman" within the meaning of that term as found under N.Y. Labor Law sec. 190(6) and pursuant to New York common law. 4. At all relevant times, as well as the Gallery, G. Hubert and J. Hubert were Morillo's employers within the meaning ofthat term as found in New York Labor Law sec. 190(3), and pursuant to New York common law, since they both: (a) had and continue to have the power to hire and fire Gallery employees; (b) supervised and controlled and continue to supervise and control Gallery employees' work schedules and/or conditions of employment; (c) determined and continue to determine the rate and method of payment of salaries, wages and commissions to Gallery employees; and (d) maintained and continue to maintain Gallery employees' employment records. 5. Upon information and belief, at the relevant times, defendant Bear Gallery Inc. (d/b/a Hubert Gallery), an art gallery, was and continues to be a corporation organized pursuant to the laws ofthe State ofnew York, with its principal place ofbusiness located at 1046 Madison Avenue, New York County, State ofnew York This Court has subject matter jurisdiction over plaintiffs claims herein under NY Labor Law sees. 190, et seq., & 215, and NY common law. 7. With respect to plaintiffs claim for retaliatory discharge against all defendants herein in violation ofny Labor Law sec. 215, through her counsel, prior to commencing this lawsuit, plaintiff sent the requisite notice to the NYS Office of the Attorney General's Office/ NYS Labor Bureau (the "AG's Office"). Annexed hereto as exhibit "A" is a true copy ofthe letter-notice dated December 5, 2013 sent to the AG's Office on behalf of plaintiff. 2

5 8. This Court has personal jurisdiction over all the defendants since, at all relevant times, defendants had and continue to have substantial contacts with and presence in New York State, and conduct continuous, systematic and substantial business in New York State, and, specifically, in New York County. II. FACTUAL AVERMENTS 9. In or about October 2008, defendants hired Morillo as a full-time sales employee and Director of the Gallery. At all relevant times, plaintiff's principal activity was the selling of the Gallery's art works, and her duties and responsibilities also included "[maintaining] client relationships, maintaining relationships with [the Gallery's] artists and helping find new [artists] to represent in the [Gallery], and making [herself] familiar with all the artwork in the [Gallery's] inventory". 10. From the beginning of Morillo's employment with defendants, through the parties' course of conduct and dealings, there was an implied contract (and/or implied-in-fact contract) (hereinafter, the "Implied Contract") that plaintiff would not have to split the commissions she earned (i.e., when Morillo, through her sole or main efforts, procured a ready, willing and able buyer for works of art) of such sales with any defendant or their employees for sales plaintiff made on behalf of the Gallery. 11. At all relevant times, while she worked at the Gallery, plaintiff's job performance at the Gallery was highly satisfactory and at no time was she accused of any wrongdoing. 12. In or about August 2012, through the parties' course of dealings, there was Implied Contract (or, contract implied-in-fact) and/or express agreement that Morillo would 3

6 receive, as her commissions (which constituted all the wages she received from defendants from that time until her termination), a 10% commission rate (on the retail price) for sales plaintiff closed where the profit was over 50% of the retail price of art pieces Morillo sold; and a 20% commission rate (on the profit) for sales plaintiff closed where the profit was less than 50% of the total retail price for art works Morillo sold. 13. At all relevant times, there was no written "agreed upon terms of employment" between Morillo and defendants as required under New York Labor Law sec. 191(c). 14. In or about September 2012, contrary to the Implied Contract and/or express agreement in effect from the beginning of Morillo's employment with defendants in October 2008, defendants unilaterally changed the commission structure, whereby Morillo's commissions would be "split" 50/50 between the sales person who, through her sole or main efforts, procured a "willing, ready and able" buyer and therefore had earned her full commissions, and the sales person/ employee who was physically working "on the floor" (or, "floor sales employee") of the Gallery on the day the buyer would present him or herself to pick up and/or pay for the art purchased. 15. Morillo protested, verbally and/or in writing, to defendants' unilateral change, i.e., the "50150 split", of the terms of payment ofher commissions in the Implied Contract and/or express agreement. 16. As a result of defendants' unilateral change to and breach of the Implied Contract and/or express agreement by splitting plaintiffs commissions 50/50 with the "floor sales employee", the sales commissions of which were fully earned through plaintiffs sole or main efforts by plaintiff's procurement of a "ready, willing and able" buyer, Morillo lost approximately $4, in the sale of five works of art. 4

7 17. From in or about early May to June 2013, solely and/or mainly through her own efforts, Morillo procured a willing, able and ready buyer for a highly valued Picasso Buste De Cranach at the sales price of$350,000.00, and thus, earned a commission in the amount of $35, (i.e., 10% of the total retail price). 18. On or about June 12, 2013, the sale of the Picasso Buste De Cranach (or the "Picasso") was consummated. 19. Pursuant to the Implied Contract and/or express agreement, plaintiff was entitled to receive 10% of the total sales price, or $35,000.00, of the Picasso. G. Hubert told Morillo that she would receive the full commission of $35, consistent with the terms ofthe Implied Contract and/or express agreement. 20. In breach of the Implied Contract and/or express agreement, defendants, and specifically G. Hubert, advised Morillo that they were going to "split [the 10% commission] with the Gallery" and give plaintiff only $17,500.00, i.e., half the commission Morillo earned for her sale of the Picasso. 21. On or about June 12, 2013 or soon thereafter, Morillo verbally complained about the "split" of the commissions for the sale of the Picasso and requested that she be paid the full $35, commission she earned. 22. In addition to her verbal protests, in a series of from June 16th to June 20, 2013, and despite plaintiffs request that she be paid her fully earned commission of$35,000.00, in breach of the Implied Contract and/or express agreement, defendants unilaterally decided that Morillo would only receive $17, for the sale. Attached hereto as exhibit "B" is a copy of the June 16th to 20, exchange. 5

8 23. On July 12, 2013, via , Morillo demanded payment of the $35, commission in full and made a good faith complaint that she believed defendants' "splitting" of her fully earned commission for the Picasso, and complaint and/or opposition to other unilateral decisions defendants intended to institute as to how commissions would be split, violated NY Labor Laws sees. 190, et seq. (or, the "NY Labor Law"). Annexed hereto as exhibit "C" is a copy of plaintiffs July 12, As evidence of defendants' retaliatory animus against Morillo for plaintiffs verbal protests against, opposition to, and herwritten complaint that plaintiff believed, in good faith, that defendants had violated the NY Labor Law, on July 16, 2013, the Huberts sent an to Morillo stating- "[i]fthe terms of employment at [the Gallery] do not meet your satisfaction, then you should terminate your employment... [ s ]hould you decide to continue your employment, we will need you to sign the agreement forwarded to you with your paycheck on June 15th." There was no "agreement" that was ever forwarded to Morillo on June 15th. Attached hereto as exhibit "D" is a copy ofthe July 16, After plaintiff complained that she felt that she was being retaliated against, defendants advised Morillo that she would be required to a sign a proposed Sales Commission Agreement on July 19, 2013, to which Morillo complied by signing the proposed agreement on July 19th. 26. On July 20th, as further evidence of defendants' retaliatory animus, J. Hubert advised Morillo that the Sales Commission Agreement which she signed on July 19th was being "rescinded and/or terminated" and requested that "[plaintiff] leave the sales floor immediately". Attached hereto as exhibit "E" is a copy of the July 20,

9 27. On July 23, 2013, defendants terminated Morillo's employment in retaliation for requesting from defendants that she be paid her fully earned commission of $35, for her sale of the Picasso, her verbal and/or written protests against, and for her making verbal and written complaints that defendants had violated the NY Labor Law. 28. Upon information and belief, while plaintiff was suspended on or about July 20th to 23rd, the buyers, who Morillo had procured solely or mainly through her own efforts, of four (4) pieces of art (the total retail value of which is $71,000.00), picked up and/or purchased the four works of art. Thus, upon information and belief, defendants have also breached the Implied Contract and/or express agreement by failing to pay Morillo $7,100.00, or 10% of$71,000.00, to which she is entitled as fully earned commissions. 29. As a result of defendant's breach of the Implied Contract and/or express agreement, and defendants' termination of her employment, plaintiff has suffered loss of her fully earned commissions, back and front wages, embarrassment, humiliation, mental anguish, emotional and physical distress. PLAINTIFF'S 1sT CAUSE OF ACTION AGAINST BEAR GALLERY INC. d/b/a HUBERT GALLERY FOR BREACH OF THE IMPLIED CONTRACT AND/OR EXPRESS AGREEMENT. 30. Plaintiff hereby repeats andre-alleges each allegation contained in paragraphs 1 through 29 above. 31. The parties had an Implied Contract (and/or express agreement) that plaintiff would earn 10% commissions on the total retail value on sales Morillo made by procuring an able, ready and willing buyer solely or mainly through her own efforts. Defendants' unilateral 7

10 decision to pay Morillo only half (or, $17,500.00) of her earned commission of$35, on the sale of the Picasso, half the commissions (i.e., $4,920.50) plaintiff earned for the sale of the five other works of art but for which half of the commissions were paid to the sales employee "on the floor" of the Gallery when the purchasers presented themselves, and, upon information and belief, failure to pay $7, earned commissions for the sales Morillo made prior to her termination on July 23, 2013, constitutes a breach of the Implied Contract and/or express agreement to pay Morillo her fully earned commissions the total sum of which is $29, PLAINTIFF'S 2ND CAUSES OF ACTION AGAINST ALL DEFENDANTS FOR FAILURE TO PAY HER EARNED COMMISSIONS IN VIOLATION OF NY LABOR LAW sees. 190 & Plaintiff hereby repeats andre-alleges each allegation contained in paragraphs 1 through 31 above. 33. Plaintiff earned full commissions, as wages, for the total sum of $29, for the sale of the Picasso, the five other sales that were split with the "floor" sales person, and the sale, upon information and belief, of the four other art works, for which she produced willing, able and ready purchasers before her termination. Despite the parties' Implied Contract and/or express agreement that Morillo was entitled to payment of $29, as plaintiffs fully earned commissions, Defendants wilfully failed to pay Morillo her fully earned commissions in violation ofny Labor Law sees. 190 &

11 PLAINTIFF'S 3Ro CAUSES OF ACTION AGAINST ALL DEFENDANTS FOR MAKING UNLAWFUL DEDUCTIONS FROM HER WAGES IN VIOLATION OF NY LABOR LAW sees. 190, 191 & Plaintiff hereby repeats andre-alleges each allegation contained in paragraphs 1 through 33 above. 35. Plaintiff, in good faith, procured ready, willing and able buyers for the Picasso and the nine other works of art, the sales of which and plaintiff's performance of which were accepted by defendants, and for which defendants have not paid her $29, as plaintiff's fully earned commissions. Defendants' failure to pay Morillo the $29, constitutes a willful unauthorized deduction from the payment of her wages in violation ofnew York Labor Laws sees. 190, 191 & 193. PLAINTIFF'S 4th CAUSES OF ACTION AS AND AGAINST ALL DEFENDANTS FOR QUANTUM MERUIT 36. Plaintiff hereby repeats andre-alleges each allegation contained in paragraphs 1 through 35 above. 37. Plaintiff, in good faith, procured a ready, willing and able buyer for the Picasso on behalf of defendants, the sale of which and plaintiff's performance were accepted by defendants, as well as for the five other art works of which her commissions were "split" with the "floor sales employee" and the four works of art that, upon information and belief, were picked up and/or sold during the time Morillo was suspended immediately prior to her termination. Plaintiff expected compensation from defendants of her fully earned commissions the total sum of which is $29, Defendants are obligated to pay Morillo $29, in 9

12 quantum meruit. PLAINTIFF'S 5th CAUSES OF ACTION AS AND AGAINST ALL DEFENDANTS FOR UNJUST ENRICHMENT 38. Plaintiff hereby repeats andre-alleges each allegation contained in paragraphs 1 through 37 above. 39. Through plaintiffs sale of the Picasso, as well as the other nine (9) works of art, for which Morillo has not been fully compensated by defendants, defendants have been enriched by $29, at Morillo's expense. It would be against equity and good conscience to permit defendants to retain the $29, that was earned by plaintiff as commissions by her procuring ready, willing and able purchasers of the nine art works. I PLAINTIFF'S 6th CAUSES OF ACTION AS AND AGAINST ALL DEFENDANTS FOR RETALIATORY DISCHARGE IN VIOLATION OF NY LABOR LAW SEC Plaintiff hereby repeats andre-alleges each allegation contained in paragraphs 1 through 39 above. 41. Defendants wilfully terminated plaintiffs employment, in violation ofny Labor Law sec. 215, at the Gallery in retaliation for her protests against and her opposition to defendants' unilateral decision to not pay her plaintiffs fully earned commissions, and for her demand that she be paid her fully earned commission of$35, on the Picasso, as well as the commissions owed on the five (5) pieces of art that she procured (but for which her commissions were split "50/50"), and for complaining verbally and in writing that defendants had violated NY Labor Law sees. 190, et seq. &

13 PRAYER FOR RELIEF WHEREFORE, plaintiff prays that the Court empanel a jury of her peers and grant judgment to her containing the following relief: 1. An award to plaintiff of compensatory damages for emotional and physical distress, and for her actual damages, in an amount to be determined at trial for lost back and front wages, benefits and other remuneration resulting from defendants' willful retaliatory discharge of plaintiffs employment in violation ofny Labor Law sec. 215; 2. An award to plaintiff of liquidated damages, in addition to her lost back and front wages due to defendants' willful retaliatory discharge ofher employment, plus prejudgment interest pursuant to NY Labor Law sees. 198 and 215; 3. An award of $29, plus liquidated damages of$29, (100% of her fully earned commissions owed), or $59,041.00, pursuant to NY Labor Law sec. 198, plus pre-judgment interest for defendants' breach of the Implied Contract and/or express agreement and violations ofny Labor Law sees. 190, 191 & 193; 4. An award to plaintiff of her attorney's fees required for prosecuting the instant action for defendants' failure to pay her fully earned commissions and their retaliatory termination ofher employment in violation ofny Labor Law sees. 190, et seq, 198 and 215; 5. An award to plaintiff of her costs for litigating the instant action; 6. An order enjoining defendants from adversely affecting plaintiffs future employment prospects; and 7. Such other and further relief as this Court may deem just and proper. 11

14 Dated: December 6, 2013 Cornwall, New York Respectfully Submitted, LAW OFFICES OF JIMMY M. SANTOS, PLLC 12

15 EXHIBIT A

16 ~- -=hk~- LAW OFFICES OF.JThfMYM. SANTOS, PLLC Civil Rights, Labor & Employment, Civil litigation ATTORNEY AT LAW 28 Wilson Pia= Cornwall, New Yoik Phone: (845) Fax: (845) Tnnm.y M- Santos, Esq_ Direct VIA FEDERAL EXPRESS January 25, 2011 The Labor Bureau Office of the Attorney General 120 Broadway, 26th floor New York, NY Dear Sir/Madam: Re: Notice of Claim Under NY Labor Law sec. 215 Michelle L. Morillo v. Bear Gallery, Inc. d/b/a Hubert Gallery, et al. I represent Ms. Michelle Morillo, in the above, against Bear Gallery, Inc. d/b/a Hubert Gallery, and its owners, Gregory and Julie Hubert (the "defendants"). Enclosed please find a copy of Ms. Morillo's Verified Complaint which we intend to file in the Supreme Court of the State ofnew York, New York County, the week ofdecember 9th. Pursuant to NY Labor Law sec. 215(2)(b), this letter and the attached are being sent as notice to the NYS Attorney General's Office that Ms. Morillo, formerly employed by the defendants as a commission sales employee, has a claim under NY Labor Law sec. 215 for retaliatory discharge for her opposition to and complaining about defendants' violations under Article 6 of the NY Labor Law. If you have any questions, please do not hesitate to contact me at (845) Thank you for your attention to this matter. Sin~yr~,.. I I /;~ -,.._ /. -N[ S?B1os, Esq. Enc. ~ cc: Ms. Michelle L. Morillo / 1

17 EXHBITB

18 From: "Julie Hubert" <bubcrthomc- {i;uu.nct> Date: June 20, 2013, 11:06:33 AM CDT To: "Michelle Morillo" <michcl!e(q_.hubertgallcry.com>, "GREG" <u_rcghubert._..... homc-t(/~gmail.con1> Subject: Re: Picasso Buste de Femme D'apres Cranach sale Reply-To: buberthomcrd:att.ner Michelle, Your statement that you were the sole contact is erroneous, as Greg spoke with Mr. O'Brien and his wife in person at the gallery, discussing the Picasso in detail for a significant period of time, and then later provided him an with condition information as well as a discussion of our asking-price and why the gallery would not be discounting the price by much. I of :34 PM

19 ~~~ ~~w ~~ ' ~"""" 1.J apl "" '-.-lall<ll-011 Mit: rmps://rnau.google.corrvmall/u/urtui=l&lk=4y3423da68&view=pt... There is no whim or folly at play here; Greg got involved in the recent Picasso sale as we deemed appropriate. As you are well aware, we are currently in dialogue with one of your clients regarding a purchase they would like to reverse; the main argument they are pursuing now, through legal remedies, is how the artwork was presented to them, including what specific artistic/technical information was given to them at the time of the sales negotiation about how the artwork was created. For this particular sale, you were indeed the primary and sole contact. And yet you do not have the technical knowledge and expertise to now defend the sale with the client's lawyer. By Greg involving himself in the sale ofthe Picasso Cranach, he is providing due diligence in circumventing future complications in this current sale. I am unsure what "agreement" you speak of referring to who you split commission with, and under what circumstances. In the past, in all cases of splits, it has been decided upon by Greg and/or me, appropriate to each particular sale, after the sale is complete. It is no secret that you have not agreed with us on many of the split commissions that have taken place, but we feel we have always been fair and done what was appropriate and made sense for each sale. You also felt that the pay structure change which went into effect on September 1st, 2012 would be detrimental to you and that you would make less money, and that you would have preferred us not to introduce the new pay structure. It should be noted that for the 12-month period ended June 1, 2013, your W-2 earnings equaled $109, For the prior 12-month period ended June 1, 2012, your earnings were$ 62, Although it may be important for us to be aware of your preferences, we continue to make decisions as we see fit. In the case of the pay structure debate, you certainly benefitted fmancially in a substantial way from our fmal decision to move forward with it, disregarding your preference not to change the pay structure. In every decision we make, we do so in good faith. The Picasso Cranach commission will be fmalized as a split commission. You will receive $17,500 in 3 disbursements of$5,500, $5,500 and $6,500, with all appropriate payroll taxes and healthcare expenses withheld, on the next three paydays following the delivery and acceptance ofthe artwork into the home of the client. Julie and Greg Sent from my Verizon Wireless BlackBerry From: "Michelle Morillo" Date: Tue, 18 Jun :06: To: ReplyTo: "Michelle Morillo" Subject: Re: Picasso Buste de Femme D'apres Cranach sale Good afternoon Julie, Regarding the Picasso sale: From the moment Mr. O'Brien and I met, then began discussing the Picasso which lead to the two of us negotiating the price until he forwarded payment, I was his primary and sole contact. Mr. O'Brien responded only to me and negotiated with me. As in all sales, Greg Hubert and the Gallery staff are there to provide support and backup 2 of6 7/ :34PM

20 information to the commissioned salespeople, but it is the salespeople who engage in the negotiations with the clients. And it is the sales people who earn the commission when a sale is procured. As what has been the terms of my agreement and practice with Hubert Gallery for the past year, I am a salesperson on commission and only split my commission with Lydia, the only other commissioned salesperson, if and when we procure a deal together. On May 20th on a phone call Greg confmned my commission for this deal would be at the very least $30,000. It is not our agreement nor has there ever been a situation where I have shared my commission with the Gallery or any Gallery staff other than Lydia, the only other commissioned salesperson. To do so now as you are suggesting would be changing our agreement during the transaction of a sale and retroactive to a sale. Regards, Michelle From: Julie Hubert Sent: Tuesday, June 18, :42 AM To: Michelle Morillo ; GREG Subject: Re: Picasso Buste de Femme D'apres Cranach sale Michelle, Please note that nothing about the commission structure is changing for this sale, and nothing is being changed retroactively. Our practice of split commissions when appropriate is not new, and you have experienced split commissions numerous times in the last year. This sale was secured by a group effort including a good deal of time and energy required-not only by yourself, but by Greg, myself and Laura. After Mr. O'Brien visited the gallery, you were handed the research on the piece. Greg provided, both in person and in direct communication with the client, the expertise and knowledge in support of creating a sale where the client had full information about the condition of the piece and could feel confident in his purchase. You will receive commission I 2, as with other splits. This works out to a $17,500 commission due to you. You will receive this commission in 3 disbursements of$5,500, $5,500 and $6,500, with all appropriate payroll taxes and healthcare expenses withheld, on the next three paydays following the delivery and acceptance of the artwork into the home of the client. Julie and Greg Sent from my Verizon Wireless BlackBerry From: "Michelle Morillo" Date: Mon, 17 Jun :5 9: To: Julie Greg ReplyTo: "Michelle Morillo" <miche11e( Y.hubertgallery.com> Subject: Re: Picasso Buste de Femme D'apres Cranach sale 3 of6 7/ :34PM

21 Greg and Julie, In response to your regarding my recent sale of the Picasso Buste De Femme, your terms are unacceptable. Your is inconsistent -by your own words- in your statement of the commission structure policy. If the commission structure is to be changed, it cannot be changed during a sale and retroactive to my sale of the Picasso. That commission must be based on our normal practice in effect now. By the policy that has been in place, I am due 1 0 percent commission of the sale of the Picasso Buste De Femme, payment effective as soon as the art is delivered. Regards, Michelle From: From: Julie Hubert Sent: Monday, June 17, :57AM To: Michelle Morillo ; Greg Hubert Subject: Re: Picasso Buste de Femme D'apres Cranach sale Hello Michelle, We are all pleased the sale of the Picasso Cranach went through and is nearly final. It was a group effort by several of us as the gallery: Greg, you, myself, and Laura. We all spent a good deal oftime and effort to secure the sale, and as such, the commission on the Picasso Cranach is a split commission. You will receive 10% I 2, as with other splits. This works out to a $17,500 commission due to you. You will receive this commission in 3 disbursements of$5,500, $5,500 and $6,500, with all appropriate payroll taxes withheld. Your July 31st paycheck will contain withholding for both August and September healthcare payments in advance. It appears the gallery is in position to foster more big-ticket artwork sales in the future. As such, the commission structure needs to be revisited for these higher level sales. There is a higher capital stake in this more valuable artwork, and the commission percentage needs to reflect that. Moving forward, sales that finalize after June 30, 2013, will be commissioned at new rates. 10% commission will be due on the first $50,000 worth of profit (ie $5,000 commission due). For the next $50,000 worth of profit, 5% of commission will be due. (ie up to $2,500}. For any remaining profit in excess of $100,000, the gallery will pay 2% commission. In addition, there are other pay structure changes we are planning for the immediate future, that 4 of :34PM

22 we can apprise you of now. We are not satisfied with the fact that information does not flow freely between sales consultants, regarding clients who visit , etc. In order to build a culture of teamwork, and to make sales consultants vested in every sale that occurs, we will be splitting all commissions on all sales, starting July 1st. Ours is a gallery of"walk-in" and "pop-in" clients, and our sales consultants' paychecks should not be contingent on who happened to "walk-in" Tuesday vs who walked in Thursday. We need sales consultants to be positioned at the front desk every hour the gallery is open, even ifthe particular day/time has not proved to be "fruitful" thus far. And sales consultants need to be vested in every sale that might possibly occur, and work to make the sale. The sales consultant who closes the sale will receive 60% of the commission, with the other sales consultant on staff receiving 35%. The remaining 5% will be split between support staff at the end of each season. This 60/35/5 split takes some ofthe "hit-or-miss" out of which day a sales consultant is scheduled to work, as the benefit of the closed sale is felt by all. In order to accommodate your month off for August, August will revert to the current commission structure as is, since you will not be scheduled any hours in August, as previously requested by you. We look forward to a successful second half of Julie and Greg From: Michelle Morillo To: Greg Hubert Sent: Sunday, June 16, :38PM Subject: Picasso Buste de Femme D'apres Cranach sale Dear Julie and Greg; Following up from our conversation on Friday on the sale I procured of the Picasso Buste De Femme D'Apres Cranach LeJeune: As per your request, as a one time exception to our normal agreement and practice of full payment of 10% commission upon payment and delivery of art, I will accept three equal part payments for this commission commencing as soon as the Picasso is safely delivered to the clients home in Chicago next week. The Picasso was sold at $350,000, which brings my commission to $35,000. The payments to be scheduled in three equal amounts, for the paychecks of June 30, July 15th and July 30th. Thank you and congratulations to us all on this terrific deal! Michelle Jimmy Santos To: michelle morillo Bee: Jimmy Santos Tue, Jun 25, 2013 at 11:38 PM 5 of6 7/11/2013 4:3

23 EXHIBIT C

24 7/24/13 11:45 PM Subject: Picasso commission owed From: To: Bee: Date: michelle morillo Friday, July 12, :11 PM Friday, July 12,2013 Greg and Julie: Please be advised that I expect full payment, i.e., $35,000.00, and not the $17, that you have offered, on the sale of the Picasso Buste de Femme D'Apres Cranach ("the Picasso Buste") that I procured alone. It is my understanding that, under NY Labor Law (NY Labor Law sees, 190, et seq., or "Article 6") and NY common law, my commissions are earned on any item sold fully by my own efforts when I "produce a [buyer] ready and willing to enter into a contract". In your dated June 17,2013, you unilaterally changed the "split" structure to 60%/ 35%/ & 5%. It is my understanding that your unilateral "change" in the "split" structure is contrary to Article 6 and NY common law. As you are fully aware, there is no written agreement between Hubert Gallery ("Hubert") and myself with respect to allowing Hubert to unilaterally change and/ or modify the. commission structure/ scheme. Similarly, in Hubert's "Pay Structure for Sales Consultants, July 2013" (which reflects the proposed new commission structure in your June 17, ), Hubert has unilaterally modified and/ or changed the "commission structure" as it is not an agreement signed between Hubert and myself, which, according to my research, is contrary to Article 6 and NY Common Law. Please be advised that I reject, in full, Hubert's unilateral change and/ or modification to Hubert's previously existing commission structure/ scheme, purportedly effective July 1, Again, as I stated previously, I expect to be paid the total $35, on the sale that I procured of the Picasso Buste, mostly or totally through my own efforts. Also, be advised that I have and/ or will deposit the 1st check that I have been issued for the commission on the Picasso Buste (which you claim should only be $17,500.00, and to which I dispute) under the following terms: "This check is deposited under protest, without pnjudice and with reseroation of a!! rights of the pqyee against drawer o/ this check." Lastly, please be advised that any form of retaliation against me for the issues raised herein is prohibited under the NY Labor Law (specifically, NY Labor Law sec. 215). Please advise as to whether you will be paying me the full commission owed me, i.e., $35,000.00, for my sale of the Picasso Buste by the dose of business [5PM] this Monday, July 15. about: blank Page 1 of 2

25 7/24/13 11:45 PM Thank you for your prompt attention. Michelle about: blank Page 2 of 2

26 EXHIBITD

27 uu.p;tt u:>-iijgo.mau.yi:llloo.commeojiawicnt.ranu=arncnuokupgp:mmau Subject: [No Subject] From: To: Cc: Date: Tuesday, July 16,2013 6:47PM Michelle, Not sue if you came by the gallery this afternoon, but your paycheck of July 15th is in the back drawer of the assistant desk, as usual. It contains the second installment of the Picasso commission, as outlined in many previous s. We have always felt our policies and commissions are fair, and we are sorry you are not pleased with our decision that this sale was a split commission situation. Regarding the separate issue ofthe updated commission structure and splits moving forward from July 1st, for which we gave you advance notice, you are stating you "reject in full" our new policy structure. If the terms of employment at Hubert Gallery do not meet your satisfaction, then you should terminate employment. Should you decide to continue.employment, we will need you to sign the agreement forwarded to..-. you with your paycheck back on June 15th, which outlined the policy change. Julie will be in on Thursday and will print out a copy for both parties to sign. Julie and Greg ~- 1 ofl 7/18/2013 1:54PM

28 EXHIBIT E

29 7/25/13 12:29 AM Subject: Re: FOR THE IMMEDIATE ATTENTION OF MICHELLE MORILLO From: To: Cc: Date: Saturday, July 20, :03 AM The date below is revised to read today, SATURDAY, JULY 20th, 2013 at 10:50am. I apologize for the error. From: Sent: Saturday, July 20, :51 AM To: Michelle Morillo; Michelle Morillo Cc: Greg Hubert Subject: FOR THE IMMEDIATE ATTENTION OF MICHELLE MORILLO FOR THE IMMEDIATE ATTENTION OF MICHELLE MORILLO Michelle, You are hereby notified and advised that as of!0:50am, Saturday, July 14th, 2013, Hubert Gallery is rescinding and/or terminating the Sales Commission Agreement both parties signed yesterday at or about Spm, July 19, We operated in good faith yesterday in regard to our intention to provide you with a satisfactory document, so that you could continue to spend time on the sales floor. However, it has been decided it is prudent and in the best interest of both parties to allow our lawyer to finish reviewing it in its entirety before it is put into place. As you continually both imply and state that, even as late as yesterday morning at 11:48am (July 19, 2013), you are unaware of the written agreement all parties were operating under that was dated September 10, 2012, this would mean that, from your point of view, at you are operating under no written agreement at all. Because of your continued denial of the existence of the September 2012 document, we must request that you leave the sales floor immediately until such time as we can present you with an written agreement to sign that has been thoroughly reviewed by our attorney. Please hand in your keys to Grace Moore. They will be returned after a new sales agreement is in place. We will advise you when we have a final document for you to sign regarding sales commissions and payment structures. Julie Hubert on behalf of Hubert Gallery about: blank Page 1 of 1

30 ATTORNEY VERIFICATION STATE OF NEW YORK ) ) ss: COUNTY OF ORANGE ) JIMMY M. SANTOS, ESQ., an attorney admitted to practice before the Courts of the State of New York, affirms the following statements are true under the pains and penalties of perjury. Affirmant is the attorney of record for plaintiffherein in the within action. Affirmant has read the foregoing Plaintiff's Verified Complaint dated December 6, 2013, knows the content thereof, and the same is true to affirmant's own knowledge, except as those matters stated to be alleged upon information and belief, and that those matters affirmant believes to be true. This verification is made by the affirmant, and not by the answering plaintiff, because the answering plaintiff is not located in the county wherein your affirmant maintains an office. The grounds of affirmant' s belief as to all matters not stated upon affirmant' s knowledge are as follows: statements of the answering plaintiff; documents within the possession of plaintiff and/or your affirmant; and affirmant's general investigation into the facts of this case. Dated: December 6, 2013 Cornwall, New York Sworn to Me this 6th Day _,---:- Of December 2013 Notary Public VANESSA HILL Notary Public, State of New York Qua!t.'ied in Orange County Registration No. 01 Hl Commission Expires February 12,20j_ 1

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