FILED: NEW YORK COUNTY CLERK 05/21/2013 INDEX NO /2012 NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 05/21/2013

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1 FILED: NEW YORK COUNTY CLERK 05/21/2013 INDEX NO /2012 NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 05/21/2013 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK TONY PARKER, Plaintiff, Index No /2012 W.i.P. CLUB, INC., BARRY MULLINEAUX, COLLECTIVE HARDWARE, INC., JOHN BAKHSHI, LIMA KAY, HIRUKLTNI SAI, JOHN C. BEST, FRANK PORCO, MERLIN B. WILLIS, 150 RFT VARICK CORP., 150 RFT VARICK BASEMENT LLC, W & M OPERATING, L.L.C., and ALLSTAR SECURITY &CONSULTING INC. VERIFIED ANSWER AND CROSS CLAIMS TO SECOND AMENDED COMPLAINT AND AMENDED THIRD-PARTY COMPLAINT Defendants. 150 RFT VARICK CORP., 150 RFT VARICK BASEMENT LLC and BARRY MULLINEAUX, Third Party Index No /2013 Third-Party Plaintiffs, -against- -against- AUBREY GRAHAM DRAKE a/k/a DRAKE, and CHRISTOPHER MAURICE BROWN a/k/a CHRIS BROWN, Third-Party Defendants. Defendants 150 RFT Varick Corp. ("Varick Corp."), 150 RFT Varick Basement LLC ("Varick Basement") and Barry Mullineaux (collectively, the "Varick Defendants"), by their attorneys Garvey Schubert Barer, answer Plaintiff's Second Amended Verified Complaint (the "Amended Complaint" or "Am. Comp.") herein as follows: 1. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 1 of the Amended Complaint. 1

2 2. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 2 of the Amended Complaint, except admit that that Plaintiff is a professional basketball player. 3. Admit the allegations of Paragraph 3 of the Amended Complaint. 4. Admit the allegations of Paragraph 4 of the Amended Complaint. 5. Deny the allegations of Paragraph 5 of the Amended Complaint, except admit that Mr. Mullineaux is responsible for the day-to-day management of Greenhouse and W.I.P., and that Mr. Mullineaux is listed on Varick Corp.'s liquor license. 6. Deny the allegations of Paragraph 6 of the Amended Complaint, except admit that W.I.P. is located in the basement of the premises at 150 Varick Street, New York, New York. 7. Deny the allegations of Paragraph 7 of the Amended Complaint. 8. Deny the allegations of Paragraph 8 of the Amended Complaint. 9. Deny the allegations of Paragraph 9 of the Amended Complaint. 10. Deny the allegations of Paragraph 10 of the Amended Complaint. 11. Deny the allegations of Paragraph 11 of the Amended Complaint, except admit that Mr. Porco is listed on Varick Corp.'s liquor license. 12. Deny the allegations of Paragraph 12 of the Amended Complaint. 13. Admit the allegations of Paragraph 13 of the Amended Complaint. 14. Admit the allegations of Paragraph 14 of the Amended Complaint. 15. Admit the allegations of Paragraph 15 of the Amended Complaint. 16. Deny the allegations of Paragraph 16 of the Amended Complaint. 17. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 17 of the Amended Complaint. 2

3 18. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 18 of the Amended Complaint. 19. Deny the allegations of Paragraph 19 of the Amended Complaint. 20. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 20 of the Amended Complaint. 21. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 21 of the Amended Complaint, except deny that W.I.P. was operating illegally, and deny that W&M Operating, L.L.C. ("W&M") was permitted or required to evict W.I.P. under RPAPL 711(5). 22. Admit the allegations of Paragraph 22 of the Amended Complaint. 23. Admit the allegations of Paragraph 23 of the Amended Complaint. 24. Admit the allegations of Paragraph 24 of the Amended Complaint and respectfully refer the Court to the document referenced therein for the complete contents thereof. 25. Deny the allegations of Paragraph 25 of the Amended Complaint. 26. Deny the allegations of Paragraph 26 of the Amended Complaint. 27. Deny the allegations of Paragraph 27 of the Amended Complaint. 28. Deny the allegations of Paragraph 28 of the Amended Complaint 29. Deny the allegations of Paragraph 29 of the Amended Complaint, except admit that W.I.P. is located in the basement of the premises at 150 Varick Street, New York, New York. 30. Deny the allegations of Paragraph 30 of the Amended Complaint, except admit that W,I,P, is located in the basement of the premises at 150 Varick Street, New York, New York. 3

4 31. Deny the allegations of Paragraph 31 of the Amended Complaint, except admit that there was an altercation at W.I.P. on or about the night of June 13-14, Dcny knowlcdgc or information sufficient to form a belief as to the truth of the allegations of Paragraph 32 of the Amended Complaint, except admit that Drake and Brown were present at W.I.P. on or about the night of June 13-14, Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 33 of the Amended Complaint. 34. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 34 of the Amended Complaint. 35. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 35 of the Amended Complaint. 36. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 36 of the Amended Complaint. 37. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 37 of the Amended Complaint. 38. Deny the allegations of Paragraph 38 of the Amended Complaint, except admit that Drake and Brown were present at W.I.P. on or about the night of June 13-14, Deny the allegations of Paragraph 39 of the Amended Complaint. 40. Deny the allegations of Paragraph 40 of the Amended Complaint. 41. Deny the allegations of Paragraph 41 of the Amended Complaint. 42. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 42 of the Amended Complaint. 43. Deny the allegations of Paragraph 43 of the Amended Complaint.

5 44. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 44 of the Amended Complaint. 45. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 45 of the Amended Complaint, except admit that an altercation took place at W.I.P. on or about the night of June 13-14, 2012 and deny that there were any gunshots fired at W.I.P. during the altercation in question. 46. Admit the allegations of Paragraph 46 of the Amended Complaint. 47. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 47 of the Amended Complaint. 48. Deny the allegations of Paragraph 48 of the Amended Complaint and respectfully refer the Court to the documents referenced therein for the complete contents thereof. 49. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 49 of the Amended Complaint and respectfully refer the Court to the document referenced therein for the complete contents thereof. FIRST CAUSE OF ACTION 50. Deny the allegations of Paragraph 50 of the Amended Complaint. 51. Deny the allegations of Paragraph 51 of the Amended Complaint. 52. Deny the allegations of Paragraph 52 of the Amended Complaint. 53. Deny the allegations of Paragraph 53 of the Amended Complaint. SECOND CAUSE OF ACTION 54. The Varick Defendants repeat and reallege each of their responses to Paragraphs 1-53 as if fully set forth herein. 55. Deny the allegations of Paragraph 55 of the Amended Complaint. 5

6 56. Deny the allegations of Paragraph 56 of the Amended Complaint. 57. Deny the allegations of Paragraph 57 of the Amended Complaint. 5~. Deny the allegations of Paragraph 58 of the Amended Complaint. THIRD CAUSE OF ACTION 59. The Varick Defendants repeat and reallege each of their responses to Paragraphs 1-58 as if fully set forth herein. 60. Deny the allegations of Paragraph 60 of the Amended Complaint. 61. Deny the allegations of Paragraph 61 of the Amended Complaint. 62. Deny the allegations of Paragraph 62 of the Amended Complaint. 63. Deny the allegations of Paragraph 63 of the Amended Complaint. 64. Deny the allegations of Paragraph 64 of the Amended Complaint. 65. Deny the allegations of Paragraph 65 of the Amended Complaint. FOURTH CAUSE OF ACTION 66. The Varick Defendants repeat and reallege each of their responses to Paragraphs 1-65 as if fully set forth herein. 67. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 67 of the Amended Complaint. 68. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 68 of the Amended Complaint. 69. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 69 of the Amended Complaint, except deny that there was an illegal club being operated on the premises at 150 Varick Street, New York, New Yorker.:~

7 70. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 70 of the Amended Complaint, except deny that there was an illegal club being operated on the premises at 150 Varick Strcct, New York, New York and respectfully refer questions of law to the Court. 71. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 71 of the Amended Complaint, except deny that there was an illegal club being operated on the premises at 150 Varick Street, New York, New York. 72. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 72 of the Amended Complaint. 73. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 73 of the Amended Complaint. FIFTH CAUSE OF ACTION 74. The Varick Defendants repeat and reallege each of their responses to Paragraphs 1-73 as if fully set forth herein 75. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 75 of the Amended Complaint, except admit that Allstar was the provider of security services at the W.I.P. club pursuant to an agreement between Allstar and Varick Corp. and respectfully refer the Court to that agreement for the terms thereof. 76. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 76 of the Amended Complaint. 77. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 77 of the Amended Complaint.

8 78. Deny knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 78 of the Amended Complaint. AFI+'IRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE 79. The Amended Complaint fails to state a cause of action against the Varick Defendants. SECOND AFFIRMATIVE DEFENSE 80. A complete defense exists to the claims alleged in the Amended Complaint founded upon documentary evidence. THIRD AFFIRMATIVE DEFENSE 81. Plaintiff has failed to join all necessary and indispensable parties. FOURTH AFFIRMATIVE DEFENSE 82. That if Plaintiff sustained any injuries and/or damages as alleged in the Amended Complaint, such injuries and/or damages were caused in whole or in part by Plaintiffls own negligent and/or culpable conduct. FIFTH AFFIRMATIVE DEFENSE 83. That any damages to which Plaintiff may be entitled should be diminished in the same proportion as Plaintiff's own negligent and/or culpable conduct bears to the total negligent and/or culpable conduct responsible for the damages sustained. SIXTH AFFIRMATIVE DEFENSE 84. That at the time of the incident as alleged in the Amended Complaint, Plaintiff was engaged in activity of which he knew the hazards, inherent risks and dangers thereof and Plaintiff voluntarily assumed and accepted the risks inherent in engaging in such activity. 8

9 SEVENTH AFFIRMATIVE DEFENSE 85. That if Plaintiff sustained any injuries andlor damages as alleged in the Amended Complaint, such injuries and/or damages were caused by the negligent, culpable and/or wrongful actions and/or inactions of third parties over which the Varick Defendants had no control. EIGHTH AFFIRMATIVE DEFENSE 86. That if Plaintiff sustained any injuries and/or damages as alleged in the Amended Complaint, such injuries and/or damages were caused by the unforeseen and unforeseeable actions and/or inactions of third parties over which the Varick Defendants had no control. NINTH AFFIRMATIVE DEFENSE 87. Plaintiff failed to mitigate his damages. TENTH AFFIRMATIVE DEFENSE 88. That if Plaintiff sustained any damages as alleged in the Amended Complaint, the Varick Defendants' liability, if any, shall be limited in accordance with Article 16 of the CPLR. ELEVENTH AFFIRMATIVE DEFENSE 89. That in the event Plaintiff recovers a judgment against the Varick Defendants, then such judgment must be reduced pursuant to CPLR 4545(c) by those amounts which have been or will, with reasonable certainty, be replaced or indemnified in whole or in part, for any past or future claimed economic loss, from any collateral source, including, but not limited to, insurance, social security or workers' compensation. TWELFTH AFFIRMATIVE DEFENSE 90. That if Plaintiff sustained any damages as alleged in the Amended Complaint, then the Varick Defendants' liability, if any, shall be limited in accordance with Article of the New York General Obligations Law. D

10 THIRTEENTH AFFIRMATIVE DEFENSE 91. The Varick Defendants reserve the right to add additional affirmative defenses, as appropriate, when additional information bccomcs available through discovery. FOURTEENTH AFFIRMATIVE DEFENSE 92. The Amended Complaint is an improper pleading as Plaintiff has failed to seek leave to amend his pleading in accordance with the CPLR. AS AND FOR A FIRST CROSS-CLAIM AGAINST DEFENDANT ALLSTAR SECURITY &CONSULTING, INC. 93. The Varick Defendants incorporate by reference the allegations of paragraphs 1-92 as if fully set forth herein. 94. The Amended Complaint alleges, inter alia, that Plaintiff sustained injuries on or about June 14-15, 2012 as a result of the acts and/or omissions of all of the Defendants, which caused Plaintiff damages. 95. Upon information and belief, if it is determined that Plaintiff sustained injuries and/or damages as a result of the negligence, carelessness, recklessness, acts, omissions, culpable conduct and/or breaches of duty and/or warranty by the Defendants, such injuries and/or damages were caused in whole or in part, by Defendant Allstar, without any wrongdoing on the part of the Varick Defendants contributing thereto. 96. By reason of the foregoing, if any judgment or verdict is recovered against the Varick Defendants, then the Varick Defendants are entitled to contribution from, and judgment over and against, Defendant Allstar equal to the proportionate share of responsibility as is adjudged between all the Defendants herein. 10

11 AS AND FOR A SECOND CROSS-CLAIM AGAINST DEFENDANT ALLSTAR SECURITY &CONSULTING, INC. 97. The Varick Defendants incorporate by reference the allegations of paragraphs 1-96 as if fully set forth herein. 98. Upon information and belief, if it is determined that Plaintiff sustained injuries and/or damages as a result of the negligence, carelessness, recklessness, acts, omissions, culpable conduct and/or breaches of duty and/or warranty by the Defendants, such injuries and/or damages were caused entirely by Defendant Allstar, without any wrongdoing on the part of the Varick Defendants contributing thereto. 99. By reason of the foregoing, the Varick Defendants are entitled to full indemnity from, and judgment over and against, Defendant Allstar for all of any judgment or verdict that Plaintiff may recover against the Varick Defendants, together with all attorneys' fees, costs and expenses incurred by the Varick Defendants herein. AS AND FOR A THIRD CROSS-CLAIM AGAINST DEFENDANT ALLSTAR SECURITY &CONSULTING, INC The Varick Defendants incorporate by reference the allegations of paragraphs 1-99 as if fully set forth herein Upon information and belief, Allstar was, and is, a domestic business corporation organized under the laws of the State of New York (New York Department of State ID # ), with its principal place of business located at 108 West 39th Street, 4th Floor, New York, NY, Allstar's Chairman or Chief Executive Officer is listed in corporate filings as Michael Hesekiel Upon information and belief, Allstar is engaged in the business of providing security and security-related consulting services as an independent contractor. 11

12 103. On or about the evening of June 13, 2012 and/or the early morning hours of June 14, 2012, an alleged altercation involving numerous individuals occurred at the Venue, in which Plaintiff alleges to have suffered personal injuries (the "June 14 Altercation") 104. At the time of the June 14 Altercation, Allstar was the exclusive provider of security services at the W.I.P. club, pursuant to a W.I.P. Security Service Contract entered into between Allstar and Varick Corp. d/b/a W.I.P. on November 15, 2011 (the "Allstar Contract," attached as Exhibit A). See Ex. A, Under the Allstar Contract, Allstar was required to "provide properly trained and certified...uniformed...and un-armed guard protection services for [W.I.P.]" for the express purpose of "protecting, in a professional manner, [W.I.P.]'s property, employees, and other persons on the property of [W.I.P.]." Ex. A, 1. Allstar is responsible for employing, paying and training the security staff provided to W.I.P., and such staff "is personnel of [Allstar], an independent contractor, and shall, at all times, be subject to the direct supervision and control of [Allstar]." Id., Further, as noted, Allstar has the "sole and exclusive right to provide the security services at [W.I.P.]." Id., 6. The Allstar Contract specifically precludes Varick Corp. from permitting any other individual or entity -- including Varick Corp. -- to provide security services at W.I.P. Id On the night of June 13-14, 2012, Allstar provided all of the security personnel on staff at W.I.P., in accordance with the Allstar Contract Because Allstar assumed sole and exclusive responsibility for providing, controlling and supervising the security staff at the W.I.P. club, the parties intended that Allstar would defend, indemnify and save harmless Varick Corp. and its officers, directors, employees, 12

13 and representatives, from and against any and all claims, expenses (including attorney's fees) and/or liability "arising from or out of Allstar's provision of security services at W.I.P. The Allstar Contract expressly provides that Allstar shall: Id., 5 (emphasis added). [D]efend, indemnify, and save [Varick Corp.] and [its] landlord, and their respective officers, directors, employees, and representatives, harmless (a) from and against any and all claims, actions, damages, liability, and expense, including reasonable attorney's fees, in connection with loss of life, personal injury, and/or damage to property arising fro~n or out of the provision of security services under this Agreement by [AllstarJ or its personnel Venue [sic], (b) from any and all claims of sole contribution or intentional acts or omissions of [Allstar's] personnel at the Venue, [Allstar] shall not be obligated to [W.I.P.] under this indemnity to the extent that a claim is made as a result of acts, omissions or negligence on the part of [W.I.P.] or its officers or employees without any claimed acts, omissions or negligence on the part of [AllstarJ The Allstar Contract further required Allstar to obtain and keep in force and effect a policy of commercial general liability insurance that includes coverage for "assault and battery... as well as bodily injury to any persons or property damage, with a limit of at least $1 million per occurrence and $2 million aggregate." Id., Upon information and belief, Allstar maintains such a commercial general insurance policy with First Mercury Insurance Company ("First Mercury"), which was, and continues to be, in full force and effect at all times relevant to this dispute In the Amended Complaint, Plaintiff asserts claims against the Varick Defendants that plainly "arise[] from or out of the provision of security services," thereby warranting indemnification under the Allstar Contract. Ex. A, 5. Specifically, Plaintiff alleges that his injuries were caused as a result of, inter alia, the failure to have "adequate security on the premises" or "sufficient and efficient security personnel" at W.I.P. Am. Compl. 50,

14 112. Accordingly, Plaintiffls claims "arise[ ]from or out of the provision of security services" and his alleged injuries are the result of acts, omissions or negligence on the part of Allstar, as the sole and exclusive provider of -- with exclusive supervision and control over -- the security staff and services at the W.I.P. club on the date of the June 14 Altercation. Ex. A, In addition, Plaintiff has asserted a claim against Allstar directly in connection with the security services and security personnel -- including, but not limited to, their negligence, acts and/or omissions -- it provided at the W.I.P. club on the night of the June 14 Altercation. See Am. Compl. 24, Pursuant to the indemnification provision in the Allstar Contract, Varick Corp. has given notice to Allstar of the instant action, as well as notice of several other related actions filed with this Court involving the June 14 Altercation, and demanded indemnification in accordance with the terms of that agreement. A copy of Varick Corp.'s July 27, 2012 demand on Allstar is attached as Exhibit B Allstar has refused, and continues to refuse, to honor its obligation to indemnify Varick Corp. under the Allstar Contract. Copies of letters dated September 18, 2012 and February 11, 2013 from First Mercury, Allstar's insurance carrier, are attached as Exhibit C The Allstar Contract is a binding and enforceable contract pursuant to which Allstar has received all consideration due and owing Under Paragraph 5 of the Allstar Contract, Allstar is obligated to defend, indemnify and save harmless Varick Corp. and its officers, directors, employees, and representatives from and against any claims, actions, damages, liability, and expenses, including reasonable attorney's fees, in connection with personal injury and/or damage to property arising 14

15 from the provision of security services and/or acts, omissions or negligence by Allstar and its employees or agents at the W.I.P. club In the instant action, Varick Corp. has incurred, and continues to incur, expenses (including reasonable attorney's fees) in connection with defending -- and faces potential liability, which it and Defendant Mullineaux deny -- for the claims of alleged personal injury and damages arising from the provision of security services and/or the acts, omissions or negligence by Allstar and its employees or agents at the W.I.P. club Allstar has failed to indemnify, defend and save harmless Varick Corp., as required by the Allstar Contract, and therefore is in material breach of that agreement By reason of the foregoing, the Varick Defendants have been damaged in an amount to be determined at trial, with appropriate interest thereon, and such damages continue to accrue. AS AND FOR A FOURTH CROSS-CLAIM AGAINST DEFENDANT ALLSTAR SECURITY &CONSULTING, INC The Varick Defendants incorporate by reference the allegations of paragraphs 1-120, as if fully set forth herein There exists an actual controversy between the parties concerning Allstar's obligation to defend, indemnify and save harmless Varick Corp., under the Allstax Contract, for claims, actions, damages, liability and expenses at issue in this and other related actions involving the June 14 Altercation filed with this Court By reason of Allstar's foregoing breach, Varick Corp. continues to incur expenses, including reasonable attorney's fees, in the defense of this action (and the related actions), and is at risk of being held liable in some or all of these actions for significant damages arising from Allstar's provision of security at W.I.P. or the acts, omissions and/or negligence of 15

16 Allstar and its employees or agents in connection therewith on the night of the June 14 Altercation The Varick Defendants are entitled to a Declaratory Judgment pursuant to CPLR 3001, declaring that Allstar is obligated to defend, indemnify and/or save harmless Varick Corp. and its landlord, and their respective officers, directors, employees and representatives, from and against any and all claims, actions, damages, liability and expenses, including reasonable attorney's fees, in connection with this action, and the related actions, in accordance with the terms of the Allstar Contract. AMENDED THIRD-PARTY COMPLAINT AGAINST AUBREY GRAHAM DRAKE a/k/a/ DRAKE AND CHRISTOPHER MAURICE BROWN a/wa CHRIS BROWN 125. The Varick Defendants incorporate by reference the allegations of paragraphs as if fully set forth herein Upon information and belief, Third-Party Defendant Drake is a citizen of the State of California Upon information and belief, Third-Party Defendant Brown is a resident of the State of California Jurisdiction exists over Drake pursuant to CPLR 302 based on Drake's commission of a tortious act within the State of New York Jurisdiction exists over Brown pursuant to CPLR 302 based on Drake's commission of a tortious act within the State of New York Drake was present at the W.I.P. club on the night of the June 14 Altercation, and upon information and belief, was accompanied by other third parties whom Drake employed and/or over whom Drake exercised control or had a duty to control. 16

17 131. Brown was present at the W.I.P. club on the night of the June 14 Altercation, and upon information and belief, was accompanied by other third parties whom Brown employed and/or over whom Brown exercised control or had a duty to control Upon information and belief, Plaintiff is acquainted or friends with Drake and/or Brown and accompanied or joined Drake or Brown at the W.I.P. club on the night of the June 14 Altercation Upon information and belief, Drake and/or the third parties who accompanied him to W.I.P. contributed to, instigated, participated and/or engaged in the June 14 Altercation Upon information and belief, Brown and/or the third parties who accompanied him to W.I.P. contributed to, instigated, participated and/or engaged in the June 14 Altercation. FIRST CAUSE OF ACTION AGAINST THIRD-PARTY DEFENDANTS AUBREY GRAHAM DRAKE a/k/a/ DRAKE AND CHRISTOPHER MAURICE BROWN a/k/a CHRIS BROWN (Contribution) 135. The Varick Defendants incorporate by reference the allegations of paragraphs as if fully set forth herein Plaintiffls Amended Complaint alleges that "[a]ccording to the media,. Drake's entourage and Brown's entourage entered into an altercation involving bottle throwing, possible gunshots, and a general melee." Am. Comp The Amended Complaint further alleges, inter alia, that Plaintiff sustained injuries on or about June 14-15, 2012 as a result of the acts and/or omissions of all of the Defendants, which caused Plaintiff damages Upon information and belief, if it is determined that Plaintiff sustained injuries and/or damages as a result of the negligence, carelessness, recklessness, acts, omissions, culpable conduct and/or breaches of duty and/or warranty by the Defendants, such injuries and/or 17

18 damages were caused in whole or in part, by the negligence, carelessness, recklessness, acts, omissions, culpable conduct and/or breaches of duty and/or warranty of Third-Party Defendants Drake and Brown, without any wrongdoing on the part of the Vaxick Defendants contributing thereto By reason of the foregoing, if any judgment or verdict is recovered against the Varick Defendants, then the Varick Defendants are entitled to contribution from, and judgment over and against, Third-Party Defendants Drake and Brown equal to the proportionate share of responsibility as is adjudged between the Varick Defendants and Third-Party Defendants Drake and Brown. SECOND CAUSE OF ACTION AGAINST THIRD-PARTY DEFENDANTS AUBREY GRAHAM DRAKE a/k/a/ DRAKE AND CHRISTOPHER MAURICE BROWN a/wa CHRIS BROWN (Indemnification) 140. The Varick Defendants incorporate by reference the allegations of paragraphs as if fully set forth herein Upon information and belief, if it is determined that Plaintiff sustained injuries and/or damages as a result of the negligence, carelessness, recklessness, acts, omissions, culpable conduct and/or breaches of duty and/or warranty by the Defendants, such injuries and/or damages were caused entirely by Third-Party Defendants Drake and Brown, without any wrongdoing on the part of the Varick Defendants contributing thereto By reason of the foregoing, the Varick Defendants are entitled to full indemnity from, and. judgment over and against, Third-Party Defendants Drake and Brown for of any judgment or verdict that Plaintiff may recover against the Varick Defendants, together with all attorneys' fees, costs and expenses incurred by the Varick Defendants herein. 18

19 WHEREFORE, the Varick Defendants respectfully request judgment: (a) Dismissing Plaintiffs Amended Complaint in its entirety, with prejudice; (b) On the Cross-Claims against DefendAnt Allstar, in the event any judgment or verdict is recovered against the Varick Defendants, contribution from and judgment over and against Allstar equal to the proportionate share of responsibility as is adjudged between all the Defendants herein; (c) On the Cross-Claims against Defendant Allstax, full indemnity from and judgment over and against Allstar for all of any judgment or verdict that Plaintiff may recover against the Varick Defendants; (d) On the Cross-Claims against Allstar, damages for breach of contract in an amount to be determined at trial, with appropriate interest thereon; (e) On the Cross-Claims against Allstar, a declaratory judgment that Allstar is obligated to defend, indemnify and save harmless Varick Corp. and its landlord, and their respective officers, directors, employees and representatives, in connection with the claims asserted in this action and the related actions filed before this Court, in accordance with the terms of the Allstar Contract; (~ On the Third-Party Claims against each of Third-Party Defendants Drake and Brown, in the event any judgment or verdict is recovered against the Varick Defendants, contribution from and judgment over and against Drake and Brown equal to the proportionate share of responsibility as is adjudged between all the Defendants and Third-Party Defendants herein; 19

20 (g) On the Third-Party Claims against each of Third-Party Defendants Drake and Brown, full indemnity from and judgment over and against Drake and Brown for all of any judgment or verdict that Plaintiff may recover against the Varick Defendants; (h) Awarding the fees, costs and disbursements of this action; and (i) For such other, further and different relief as the Court may deem just and proper. Dated: New York, New York May 21, 2013 GARVEY SCHUBERT BARER Je Jun oon, Esq. alcol Seymour, Esq. 10 Wal Street, 20th Floor New York, New York (212) Attorneys for Defendants Barry Mullineaux, 1 SO RFT Varick Corp. and 150 RFT Varick Basement LLC NY DOCS: ~

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