Download PDF FLASH! Bars, Boobs, and Busted: 5 Years on the Road with Girls Gone Wild

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Pickup vanier. Boob nursing hoodie. Boob nursing sweater. Hardly worn. In , author Ryan Simkin took a new job as co-production coordinator for Mantra Entertainment, producer of the infamous and iconic Girls Gone Wild videos. Over the next several years, he rose through the company to become GGW founder Joe Francis' right hand man, supervising operations across America for the brand known for getting hot, young coeds to "go wild".

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Size XS in a navy blue color in great condition. Worn 2 or 3 times only. Size xs little side boob swimsuit. Never worn! Good condition! Boob brand nursing tank top - new! New York Central R. Chisholm, U. American Stevedores, Inc. Porello, U. Jump to Page. Search inside document. The Publishing 9 Defendants respectfully request that the Court strike Claim Two and Claim Three, as alleged against 10 the Publishing Defendants, with prejudice and without leave to amend.

Plaintiffs seek damages and injunctive relief, 6 through the guise of an intentional interference with contract claim, to punish the Publishing 7 Defendants for their fully-protected speech.

In , he was convicted on felony child 12 abuse and prostitution charges relating to an incident involving the filming of underage girls in 13 Florida. Ever humble, in a Fox News interview, Francis compared his 14 persecution to that of Jesus Christ and his treatment in jail to Abu Gharib.

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Francis has been 17 named in at least one restraining order and numerous civil lawsuits. By way of 18 example only, in , Francis was sued by a woman who helped him plan a Halloween party who 19 Francis allegedly threatened and cursed out, causing the pregnant woman to have a miscarriage. Readers of a popular internet blog, 23 Gawker. In May , Francis threatened another website with claims for libel and 11 tortious interference with contract for publishing reports that Francis physically attacked a pregnant 12 employee.

While Stutz sometimes provides the 24 Publishing Defendants with legal assistance, most of her work concerns general business affairs. At that time, Simkin 27 was an event coordinator responsible for managing the event venue, equipment, cameramen and 28 security for Girls Gone Wild events. Howie liked the idea and offered to help find 7 a publisher at the time, Howie had not yet founded either of the Publishing Defendants.

Simkin 8 did not state that he had signed any non-disclosure agreements or that he was in anyway prohibited 9 from making the book. In response, 3 Simkin represented that he might have entered into an employment agreement, but that if he had, it 4 did not include a confidentiality or non-disparagement clause. Simkin said 5 he was responsible for obtaining confidentiality agreements with other Mantra employees including 6 cameramen, whom Simkin managed — but that he did not sign any such agreement himself.

Stutz 11 Decl. In the weeks following the February execution of the Book 12 Agreement, Simkin, Howie and Stutz worked tirelessly to write and edit the Book. The Book was 16 complete, other than some editing, by late April Until receiving this letter, the Publishing 26 Defendants had not seen any such agreements or any other evidence that such agreements existed 27 aside from the aforementioned email from Francis.

Consumer 9 Cause, Inc. Once the first prong is shown, the 10 burden shifts to the plaintiff to demonstrate a probability of success on its claims. If this burden 11 cannot be met, the claims must be stricken. In , Section 16 Briggs 6 v. Uusi— 7 Kerttula, Cal. Its application is not, however, 9 limited to any particular claim. First, the development and publication of the Book is obviously an 21 exercise in speech.

See Lieberman, Cal. See Gritzke v. The 14 Book also contains substantial information about the well-known celebrity, Paris Hilton see Howie 15 Decl.


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Plaintiffs 24 cannot meet this burden and thus their claims against the Publishing Defendants must be stricken. Stewart 2 Title Guar. Indeed, it is ironic that pornographers such as 6 Plaintiffs would be biting the hand from which they are fed. California law states that such 12 ratings are confidential and the newspaper defendants supposedly conspired with the State Bar to 13 disclose and print that information.

The Court held that the solicitation and publication 14 of information, even information known to be confidential, was protected by the First Amendment: 15 [T]he First Amendment protects the ordinary news gathering techniques of reporters and those techniques cannot be stripped of their constitutional 16 shield by calling them tortious.

Book alleges Paris Hilton had special hiding place for drugs

The Complaint alleges that the Publishing Defendants 3 solicited information from Simkin and later printed that information in the Book. No Valid Contract Precluded Defendant Simkin from Disclosing Any 10 Information to the Publishing Defendants 11 To prevail on a claim of tortious interference with a contract, a plaintiff must establish the 12 existence of a valid, enforceable contract.

The Complaint alleges the 13 existence of a hodgepodge of supposed agreements thrown against the wall in the hopes that one 14 might apply and be enforceable. The Complaint alleges 16 the existence of a non-disclosure agreement, dated either in or , entered into by Mantra and 17 Simkin.

Plaintiffs 19 aver that Simkin was a cameraman and therefore must have signed a similar agreement. In the face of these averments, Simkin states 21 under penalty of perjury in the concurrently-filed Declaration that he was never a cameraman and 22 never signed a non-disclosure agreement in or in See Section II C , supra. The Complaint further 24 alleges the existence of an October 18, confidentiality agreement. The information that 26 Simkin disclosed to the Publishing Defendants consisted primarily of information obtained long 27 before The non-disclosure clause of this agreement 7 is unenforceable and reflects a violation California Labor laws.

Simkin performed the work, conveyed 9 the writings and submitted an invoice. Francis, however, refused to pay Simkin the due and owing 10 wages. Employers 13 cannot condition the payment of wages owed upon releases or a discount of the indebtedness. See, 14 e. Setting aside the propriety, morality 18 and legality of withholding wages due, the release in the February agreement is not enforceable. Even if the Complaint otherwise adequately stated a claim for 25 the tortious interference with an oral agreement,3 that claim would be barred by the statute of frauds.

See 7 Quelimane, 19 Cal. As set forth in the accompanying 10 declarations, the Publishing Defendants had no knowledge that Simkin was purportedly under any 11 contractual obligation not to disclose information. The Publishing Defendants were not made 14 aware of any supposed contracts that would prohibit Simkin from disclosing the information set forth 15 in the Book until mid-May Indeed, they did exactly the opposite: they required Simkin to specifically 28 represent and warrant in the Book Agreement that he was not breaching any such contract. Thus, Plaintiffs cannot show that the Publishing Defendants engaged in any intentional 4 improper acts to somehow induce Simkin to breach a contract.

In response to such lawsuits, nobody has trumpeted the 19 First Amendment more loudly than Joe Francis. Now, when the protective blare of that trumpet is 20 necessary to protect a work about Francis and the iconic Girls Gone Wild empire, Plaintiffs seek to 21 silence it. Vikram Aditya. Legal Insurrection. Scribd Government Docs. Personal Injury Lawyer Markham. Rebel X. Ares Victor S.

Book alleges Paris Hilton had special hiding place for drugs

Pravin Sinha. Ryan Felton. CJ Angat. Rizwan Khan.


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