aw Soca rxaanu ul 13 14 15 16 17 18 19 20 2 23 24 25 26 27 28 Bryan J. Freedman, Esq, (SBN 151990) Stephanie Crane Rowe, Esq. (SBN 286988) CONFORMED CO) FREEDMAN + TAITELMAN, LLP cu PY 1901 Avenue of the Stars, Suite 500 = Los Angeles, CA 90067 Telephone: (310) 201-0005 FEB 14 2018 Facsimile: (310) 201-0045 ‘Shor, Gru, execuuve Utcelek bfreedman@ifillp.com co PY srowe@fillp.com By Shaunya Bolden, Deputy Attomeys for Plaintiff Brynn Cameron SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT - UNLIMITED BC 693739 BRYNN CAMERON, an individual, Case No.: Plaintiff, COMPLAINT FOR DAMAGES vs 1, BREACH OF EXPRESS ORAL BLAKE GRIFFIN, an individual; and DOES 1 CONTRACT to 50, inclusive, 2. ALTERNATIVELY, BREACH OF IMPLIED ORAL CONTRACT AND, IMPOSITION OF CONSTRUCTIVE TRUST Defendants, 3. BREACH OF EXPRESS ORAL CONTRACT FOR SUPPORT 4. ALTERNATIVELY, BREACH OF IMPLIED CONTRACT FOR SUPPORT 5, ALTERNATIVELY, QUANTUM MERUIT. 6. DECLARATORY RELIEF DEMAND FOR JURY TRIAL 1 COMPLAINT FOR DAMAGESeo) et) ee WW 13, 4 15 16 7 18 19 20 2 2 2B 4 25 26 27 28 Plaintiff Brynn Cameron (“Cameron”) hereby complains against Defendants Blake Griffin (“Griffin”) and Does 1-50 as follows: SUMMARY OF ACTION 1. When Blake Griffin was recently traded to the Detroit Pistons, many speculated that the Los Angeles Clippers (“Clippers”) had breached their promises to him by dumping the NBA star not long after signing him to a long-term deal. Griffin himself, however, knows very well what breaching promises is all about. After all, Griffin had no problem trading Brynn Cameron, his former fiancée and the mother of his two children, for reality television star Kendall Jenner (“Jenner”). Some might say that Griffin received karmic justice by leaming of his departure on social media, the same way he ungraciously allowed Cameron to discover her “trade.” 2. This action arises from Griffin’s refusal to provide promised financial support to Cameron pursuant to their oral agreement that she would give up her career goals and aspirations to raise their children and support Griffin’s career. Griffin cared more about the glamour of dating a Hollywood celebrity than the day-to-day responsibilities of being a father and family man. Griffin once told the Los Angeles Times he wanted to be an example to his daughter about how she should expect to be treated by men. Sadly, if that is true, she should not expect to be appreciated, recognized for her value, or treated with respect. 3. Cameron and Griffin met in 2009. Cameron had just graduated from the University of Southern California (“USC”) — where she held numerous records for the women’s basketball team — and was starting a career as a sideline reporter for ABC Sports and USC, as well as running an interior design business on the side. In July 2012, Cameron joined the leading advertising firm ‘TBWA\Chiat\Day. 4, 1n2013, at Griffin's insistence, Cameron agreed to leave her career behind and dedicate her life to raising their son full-time, 5. The following July, Cameron and Griffin moved in together. At that time, Cameron and Griffin orally agreed that Cameron would continue not to work outside of the home in order to raise their children and support Griffin so that he could focus on improving his career with the Clippers so that he could carn a National Basketball Association (“NBA”) maximum contract — worth in excess of 2 COMPLAINT FOR DAMAGESw EO) et u 13 14 15 16 7 18, 19 20 21 22 23 24 25 26 27 28 $170 million, 6. As part of the oral agreement with Griffin, Cameron not only took on the traditional duties of a wife but also those of his personal assistant, meal planner, scheduler, publicist, stylist, party planner, nurse, nutritionist, branding expert, therapist, basketball and fitness consultant, and more. 7. Inexchange for those efforts, Griffin agreed that while he and Cameron lived together, they would combine their efforts and earnings and would share equally any and all property accumulated as a result of their efforts, whether individual or combined, Griffin also promised explicitly that, whatever the future might hold, he would take care of Cameron financially and provide her a home for the rest of her life, 8. The couple planned a small wedding for the weekend of July 28, 2017 in St. Barth’s, However, only a month before the wedding, which Griffin acknowledged was unfair to Cameron, he demanded she enter into a written prenuptial agreement. The prenuptial agreement contradicted their prior oral agreement, including denying her meaningful support and her share of their property in the event of a divorce. Cameron stood firm, and the wedding was postponed with one week’s notice Griffin notified guests, emailing, “Brynn and I take this commitment to each other seriously and want to censure it is done in the right way.” 9. To,demonstrate how “seriously” he was taking his commitment to Cameron, Griffin immediately embarked on a high-profile affair with Jenner. The next weekend, on what would have been his wedding day, he was partying in Las Vegas. 10. Cameron and Griffin continued to attend couple’s therapy after the wedding was postponed, but in or about August 2017, after humiliating his family by spending a very public weekend with Jenner in the Hamptons when he told Cameron he would be in Oklahoma, Griffin informed Cameron he had no intention of continuing to live with her and their children, 11. Despite Cameron's endless support for Griffin and their family, Griffin then breached their oral agreement by denying Cameron full financial support commensurate with her lifestyle and her share of their joint property. 12. As of January 2018, Cameron and their children are homeless and cash-strapped. Cameron has been forced to rely on her brother for financial support. Meanwhile, Griffin is earning 3 COMPLAINT FOR DAMAGESaur x 10 rt 12 13 14 15 16 7 18 19 20 a 22 23 24 25 26 27 28 ‘more than $200 million between his NBA contract and endorsement deals, PARTIES 13, Plaintiff Brynn Cameron (“Cameron” or “Plaintif”) is, and at all times relevant hereto was, a resident of the County of Los Angeles, State of California. 14. Defendant Blake Griffin (“Griffin” or “Defendant”) is, and at all times relevant hereto ‘was, a resident of the County of Los Angeles, State of California, Griffin is one of the top-earning athletes in the NBA. Griffin was the first draft pick for the Los Angeles Clippers (“Clippers”) in 2009 and has led the Clippers to post-season playoffs in the last six seasons. 15, Since July 2014, as set forth more fully herein, Cameron and Griffin (collectively, the “Parties”) lived together as spouses, consistently held themselves out as such, and agreed to combine their efforts and earnings and share equally the property they accumulated, 16. The true names or capacities, whether individual, corporate, associate or otherwise, of defendants sued herein as DOES 1 through 50, and each of them, are presently unknown to Cameron at this time, who therefore sues said defendants by such fictitious names. When the true names or capacities of said defendants have been ascertained, Cameron will amend this complaint accordingly. 17, Cameron is informed and believes, and thereon alleges, that each defendant designated herein as a DOE defendant is responsible, negligently or in some other actionable manner, for the events and happenings hereinafter referred to and caused injuries and damages proximately thereby to Cameron, as hereinafter alleged, out of the said defendant's own negligent conduct or through the conduct of its agents, servants or employees, or in some other actionable manner, 18, Cameron is informed and believes, and thereon alleges, that at all times herein mentioned, defendants, and each of them, were the agents, servants, employees, joint venture, and/or alter ego of their co-defendants and were, as such, acting within the scope, course and authority of said agency, employment and/or joint venture, and that each and every defendant, as aforesaid, performed the acts and conduct alleged herein directly, aided and abetted the performance thereof or knowingly acquiesced in and accepted the benefits of such acts and conduct; and therefore that each of the Doe Defendants are liable to Cameron as alleged herein. Each reference in this Complaint to “Defendants” or specifically to named Defendant, including but not limited to Griffin, also refers to all Doe 4 COMPLAINT FOR DAMAG!v Caer anee 10 rt 12 1B 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendants sued under fictitious names. 19. Venue is appropriate in Los Angeles County because it is the location of the Parties? residence, the location in which the contracts referenced herein were breached by Griffin, and the location where Cameron’s causes of action arose. FACTUAL BACKGROUN! Cameron's Career and Griffin’s Early NBA Career 20. Cameron was born and raised in Los Angeles. She attended Newbury Park High School ‘where she was a four-year varsity basketball player and three-year varsity volleyball player. She held Newbury Park High School's record for scoring for boys and girls, and her 2004 scoring average ranked 10th in the CIF Souther Section (comprised of over 585 member public and private high schools). ‘Cameron earned myriad awards and accolades as a high school basketball player, including the 2004 Adidas/EA Sports Superstar (awarded to the top 24 female high school seniot basketball players), MeDonald’s All-American nominee, the 2004 CIF Division 3A Player of the Year, 2004 Los Angeles Times Ventura/North Coast Player of the Year, 2004 and 2003 Marmonte League MVP, 2002-2004 All- CIF Southern Section first team pick, 2001 All-CIF Souther Section second team pick, Los Angeles Times Ventura/North Coast all-region selection, and Los Angeles Daily News all-area selection. Cameron also earned conference MVP and All-CIF Southern Section first team honors in volleyball in 2004. She was selected to the Ventura County Sports Hall of Fame as Newbury Park High School’s 2004 female athlete of the year. 21, Following high school, Cameron attended USC on a full basketball scholarship. As a freshman, Cameron was the USC women’s basketball team’s number one scorer, held the new USC ‘women’s basketball single-season record for three-pointers made, ranked as the number 19 scorer in the then-Pac-10 conference (“Pac-10”), ranked second in the Pao-10 in three-pointers made, held the Pac- 10 women’s basketball's ninth-best total all-time for three-pointers made in a single season, and ranked ‘number 25 in the nation in three-point field goal percentage, Cameron was named to the Pac-10 All- Freshman team and awarded All-Pac-10 honorable mention. Cameron additionally held the USC ‘women’s basketball team’s 2007-2008 season record for three-pointers made. When Cameron graduated in 2009, she was USC women’s basketball's number three all-time 3-point shooter and ranked) 5 COMPLAINT FOR DAMAGESB Sew rxau number five in 3-goint shooting percentage. 22. Cameron’s family members are also accomplished athletes, Cameron’s grandfather, Jack| Craven, and her father, Stan Cameron, played basketball at Brigham Young University (“BYU”). Her younger brother, Jordan Cameron, also played basketball at BYU his freshman year before transferring to USC to play football. Jordan Cameron went on to play professional football in the National Football League. 23. Cameron and Griffin’s mutual friend James Dunleavy introduced them in September 2009. Cameron was a recent college graduate, starting her career as a sideline reporter for ABC Sports and USC, as well as running her own interior design business on the side. Griffin was about to start his rookie season as a professional basketball player for the Clippers. 24, — Cameron was hesitant to start a relationship because she already had a two year old son and had gone through a devastating public breakup with his father. But while Cameron and Griffin ‘began socializing as friends, there was a strong mutual attraction and they soon became a couple, 28. Very soon after they began dating, however, Griffin broke his kneecap in the last preseason game of his rookie season, The injury was devastating for Griffin, The Clippers were a franchise known only for failure and Griffin had been expected to carry them into a new era; now he ‘was out for the year— and was a potential NBA bust. 26. Cameron met Griffin upon his arrival home from surgery and cared for him the entire year while she continued with her sideline reporting and decorating her clients’ homes. The situation was particularly difficult for Griffin because he was in a new city, away from the support network provided by his family and friends in Oklahoma. Griffin frequently stayed with her because her apartment did not,have stairs, and he was able to maneuver more easily there than in his home which had stairs, 27. Griffin confided in Cameron about how difficult it was for him not to be playing basketball, his fears and anxieties about his return to the NBA after his injury, and the pressure he felt as a top draft pick. While Griffin was injured and he had to endure the awful experience of watching his team play basketball without him, he and Cameron would text throughout the games. Cameron had suffered injuries and underwent surgeries in her college career. She could easily identify with Griffin's 6 ‘COMPLAINT FOR DAMAGESwe wR 10 1 12 13 14 15 16 7 18 19 20 au 22 23 24 25 26 27 28 struggle and speak with him about his fears. 28. Cameron and Griffin fell in love while they were navigating their difficult first years out of college. They bonded over their passion for basketball, but they got to know each other outside of their athletic accomplishments. Griffin and Cameron even became close with one another's families, Griffin bonded with Cameron’s son and Griffin’s family told Cameron they were so glad Griffin had ‘met someone so Kind to help through his devastating first year in the NBA. 29. Griffin credited Cameron with keeping him focused and positive through the season and his rehab. Cameron provided Griffin mental and emotional support during his injury. She also assisted with his injury rehab, including moving his heavy rehab equipment up and down the stairs in his home, While Griffin was in a brace, Cameron dropped him off and picked him up from practices, medical appointments, and meetings, juggling Griffin’s needs with her own commitments to work and her son, 30. Cameron chose not to pursue a full-time career in sports reporting and instead focused on ‘expanding her interior design business, decorating her growing list of clients’ homes. Griffin retumed the NBA for the 2010-2011 season. Griffin provided Cameron with family tickets to attend every home game, Cameron gave Griffin goals prior to each game depending on the opponent, and she and Griffin discussed his performance after each game, even when he was on the road. Griffin began to rely on Cameron's basketball expertise and analysis. 31. After July 2011, Cameron and Griffin continued to date casually but did not remain in an exclusive relationship. He spent his offseason partying and drinking. Although Cameron did not join in his party lifestyle; she remained the steady presence in Griffin's life and career, 32. Cameron decided to utilize her sports expertise in marketing, and in or about July 2012, she joined the leading advertising firm, TBWA\Chiat\Day to develop its sports marketing department. TBWA\Chiat\Day tailored the position to Cameron with her knowledge and experience in sports, and continued to grow her department as she excelled. She worked on lucrative, highly visible accounts including Adidas Soccer and Gatorade. While employed by TBWA\Chiat\Day, Cameron continued to pursue her other passions, and ran her interior design business on the side. 33. Griffin continued to rely on Cameron for advice and support, For instance, Griffin sought Cameron’s expertise in sports marketing to assist him in business decisions including lucrative a COMPLAINT FOR DAMAGESAu ® 10 W 12 13 14 15 16 17 18 19 20 2 22 23 24 25 26 27 28 endorsement deals. Top NBA players have the opportunity to enter into endorsement deals with athletic apparel brands to promote the brand’s products, especially athletic shoes. Such endorsement deals can eam players tens of millions of dollars in addition to their NBA salaries. 34, When Griffin's rookie contract with Nike ended, Griffin had to make the decision of ‘Whether to stay with Nike or to sign with other brands who were offering him more money, such as Under Armour. Griffin sought Cameron’s expert advice. Cameron advised Griffin that Nike’s Jordan Brand was a classier brand that focused not only on elite athletes but also on pillars in character in their individual sports. She advised him that, although he may make less money on the front end, by virtue of being a Jordan Brand-sponsored athlete, it would pay off by opening the door to higher-end endorsement opportunities. Griffin took her advice, and thanked her for her guidance after re-signing with Nike. And ‘when Griffin was i jured again in or about July 2012 during a scrimmage with Team USA, Griffin tumed to his constant supporter, Cameron. Cameron Has a Son with Griffin and puts Her Career on Hold to Raise 35. In November 2012 Cameron became pregnant with her and Griffin's first child, Ford. 36. _ Griffin’s primary concern, however, was his fear that he could receive negative media attention if news of the pregnancy went public. He requested the pregnancy remain secret so that he could “focus on basketball.” Cameron, as she always did, put Griffin’s career and needs first, and, obeying his instructions, hid her pregnancy not only from the public but also from her friends and co- workers 37. Despite Griffin’s reliance on Cameron through every rough patch in his life and career since they met in 2009, Griffin did not seem to care about Cameron or the baby on the way. Griffin showed no interest in being a part of the baby’s life, even after Cameron informed him the baby might potentially have health issues. Due to his behavior, in or about March 2013, Cameron asked Griffin to surrender his parental rights. If he would surrender his rights, Cameron stated she would neither seek child support nor reveal that he was the father of her son. Faced with that ultimatum, Griffin told Cameron he did not want to do that and wanted to be a part of their baby's life. 38. Cameron gained little weight during her pregnancy and successfully hid that she was expecting from all but her closest friends and family. Cameron even used her accrued time off to give 8 COMPLAINT FOR DAMAGESSew axaanunevn WW 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 birth to their son secretly, having him while on a two-week “vacation.” 39. On August 1, 2013, Cameron and Griffin’s first child, Ford Wilson Cameron-Griffin, was bom. Just a week after Ford’s arrival, Cameron was back at work. She loved her job. She had received! a raise shortly before Ford’s birth and wanted to return to work after going on a proper maternity leave. But Griffin did not want Ford to be raised by a nanny or a working mother. Griffin asked Cameron to make yet another sacrifice for his benefit and quit her job to raise Ford. 40. Cameron resisted qui because she was excelling at a job she loved and where she had] potential for a long, lucrative career. In addition, she now had two sons to support. She told Griffin that she did not want to rely on him for financial support. But Griffin promised to her that she would never have to worry about a home or money. 41. In or about August 2013, Cameron gave in to Griffin’s repeated requests, quit her job at ‘TBWA\Chiat\Day, and stopped her interior design business. Thereafter, Griffin paid Cameron a monthly allowance to cover all of her and Ford’s expenses and provided them with theit own rental in Manhattan Beach, 42. In addition to raising their son, Griffin continued to rely on Cameron for advice regarding! his career. Griffin spoke with Cameron following games to discuss his performance and team dynamics] including his mounting tension with Chris Paul. The Clippers had been Griffin's team since he was drafied and he felt like it was no longer his team. Cameron and Griffin Cohabitate ‘A, Cameron and Griffin Agree to Pool their Property and Griffin Promises to Financially Support Cameron for the Rest of Her Life 43. In pr around June 2014, Griffin asked Cameron if they could re-enter into an exclusive relationship. Griffin told Cameron that he always loved her, respected her, and he needed her in his life because he wanted to focus on his family and career. Cameron told Griffin he needed to be present as a father for their son. 44, In or about July 2014, Cameron and Griffin commenced living together. 45. Inor about July 2014, Cameron and Griffin orally agreed to the material terms under which Griffin would support Cameron commensurate with her lifestyle for the rest of her life and that 9 COMPLAINT FOR DAMAGES- Caran 10 u 12 13, 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 during the time they lived together they would combine their efforts and earnings and share equally the property they accumulated (the “Agreement”). Among the material terms unambiguously agreed to by Cameron and Griffin were, including but not limited to, the following: a. Cameron and Griffin would live together/cohabitate, b. Cameron and Griffin would treat as joint property the earnings, income, and all property acquired therewith, which resulted from all personal service, skill, effort, and work that each of them, thereafter, individually or jointly, performed, expended, or contributed during their relationship and while they lived with each other. ¢. Cameron would not pursue her own career and would reject career opportunities so that their children would not have a working mother. 4. Cameron would be the primary caregiver of Ford and any future children so that | Griffin could focus on his NBA career without the responsibility of raising children, ‘Cameron would support Griffin’s career. £ Griffin would financially support Cameron commensurate with her lifestyle for the rest of her life and provide her with a home, 46. Atthe time Cameron, Griffin, Ford, and Cameron’s son moved in together, Griffin rented a residence in Manhattan Beach (the “Manhattan Beach Rental”) and owned a home in the Pacific Palisades (the “Pacific Palisades Residence”). Griffin had purchased the Pacific Palisades Residence following Ford’s birth for the express purpose of raising his son there. ‘The family split their time between the Manhattan Beach Rental and the Pacific Palisades Residence. 47. Pursuant to the Agreement to combine their efforts and earnings and share equally the property they accumulated, Cameron and Griffin combined their finances into a joint bank account. After joining accounts, Cameron could notify their financial manager directly if she needed more than the $20,000 on her debit card at any time. Their checks bore both Griffin’s and Cameron’s names. In addition, Cameron was provided with a credit card with no limit, 48. Griffin promised to keep Cameron apprised of their financial status. When financial 10 COMPLAINT FOR DAMAGESSoca rxraueun u 12 13 4 15 16 17 18 19 20 21 22 23 24 25 26 27 28 information arrived at their home, including summaries of investments, Griffin and Cameron discussed the information together. 49. Barly on, Cameron expressed that she did not have the greatest confidence in the business acumen of the financial manager Griffin had hired, Griffin took Cameron’s advice that they should hire a new financial manager. Cameron researched established and respected financial advisors and scheduled meetings for her and Griffin, 30. Furthermore, Cameron expressed her concem to Griffin about what would happen if the couple broke up. Cameron and Griffin were now expecting a girl, their second child. Griffin responded to Cameron that not only was everything both of theirs, but they were essentially married and a family. Griffin assured Cameron, he would take care of her for the rest of her life even if they did not stay together because he was forever in debt to her for all she did for their family, 51. Cameron relied on Griffin's promises, assurances, and actions that all of their earnings and property were “theirs,” not his. B. Cameron Raises the Children, “Keeps” the Family’s Homes, and Improves the Property 52. On September 12, 2016, their daughter Finley Elaine Griffin was born. Asa demonstration that Griffin and Cameron held themselves out as spouses, and, with their children, were a family unit, they gave Finley only Griffin's surname. 53. Cameron raised their children pursuant to the Agreement, As the children’s primary caregiver, she looked after the family tirelessly, including, but not limited to: scheduling doctor appointments; preparing meals; enrolling Ford in school, sports, and extracurricular activities; shopping for clothes; getting the children ready every day; tending to them when they were sick or needy; playing with them; teaching them morals and values; disciplining them; taking them on exciting excursions and vacations; bringing them to Clippers games and Clippers children events; planning and setting up their parties; producing the family’s charity events where they could actively help and be hands-on and taking the children to other charity functions and events; taking them to church; bathing them; reading books to them; and providing them with the parental love and support every child needs. 34. Griffin was aware Cameron was spread thin now that she was raising three children and had to be available at all times to support his career. Griffin frequently expressed his admiration that u ‘COMPLAINT FOR DAMAGES10 11 12 13 14 15 16 17 18, - 20 21 22 23 24 25 26 27 28 Cameron was the “room mom” for her oldest son’s classroom, a volunteer position she had held since he ‘was in preschool, but it was a time-consuming commitment, After Finley’s birth, Griffin asked Cameron not to reprise her role as the room mom for the 2016 school year so she would have more time for him and their family. Cameron, as usual, put Griffin’s needs first and agreed. 55. In addition to being the children’s primary caregiver, Cameron performed homemaking services for the Manhattan Beach Rental and Pacific Palisades Residence, pursuant to the Agreement. 56. Cameron dramatically improved the Pacific Palisades Residence with new décor including paint, wallpaper, fixtures, and furnishings. 57. Ino about September 2016, Cameron and Griffin began to look for a new home for their expanding family, Cameron managed the search for their new home. 58. She ran errands on behalf of the family, shopped for groceries, and bought house supplies. Griffin and their family were never in need or want due to the constant work Cameron put in to fashion a comfortable home life for them. In a handmade, Ninja Turtle-themed Mother's Day card to Cameron, Griffin wrote: Dear Brynnie, I decided not to let my angst for sharing emotions keep from [sic] telling you how i feel. Obviously, we have had our ups and downs and we've been through a lot but I wouldn’t do it again any differently. Sometimes i take you and everything you do for granted but please know that i am constantly blown away by the mother, friend, daughter, sister, aunt, person, and partner you are to me and everyone that is lucky enough to call you even one of those things. I’m super excited to share this joumey with you and the rest of our family. I loved you from the beginning when it all seemed so perfect and easy but I love you even more now that we are perfectly imperfect & everything is still easy when we are together. 1 LOVE YOU. Happy Mother’s Day! -Blakey 59. From 2014 to 2017, Cameron and Griffin held themselves out as a married couple. In social settings, Cameron and Griffin would often refer to each other as husband and wife. Cameron’s son, their son Ford, and their daughter Finley were a family. 60. Griffin's agents and the Clippers organization treated Cameron as Griflin’s wife, including her at all Clippers’ spouse events. Griffin's teammates and their significant others referred to 12 ‘COMPLAINT FOR DAMAGESSoar anevn u 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 Cameron as Griffin’s wife. Cameron and Griffin explicitly held themselves out as spouses when attending Clippers events. Doe Rivers (“Rivers”), the head coach of the Clippers, and Lawrence Frank, the Executive Vice President of Basketball Operations for the Clippers, communicated with Cameron a5 Griffin’s spouse. Rivers sent Cameron gifts when she gave birth to her children and on Mother's Day. 61. Cameron and Griffin frequently discussed marriage but agreed that, since they already folt married, additional paperwork was not necessary to make their relationship official, Even though they were not married, when they filled out important documents such as medical forms, Cameron and Griffin would indicate they were married and reference the other as their spouse. 62, When their daughter Finley was bom, Griffin suddenly felt strongly that the couple should make their marriage official for their children. In or about February 2017, Griffin proposed to Cameron; she accepted. C. Cameron Supports Griffin's Career 63. Cameron was not just the mother of Griffin's children and their caregiver, She was also constant support for Griffin — his personal assistant, meal planner, scheduler, stylist, publicist, party planner, nurse, nutritionist, branding expert, therapist, cheerleader, basketball and fitness consultant and more. Griffin’s career success did not occur in a vacuum, but was an enterprise undertaken and contributed to by both Griffin and Cameron. 64, Cameron worked with Griffin to set his routine each week. The Clippers even included Cameron on all communications regarding Griffin's schedule. Cameron informed Griffin when he was available to meet with his trainers, agents, physical therapists, and production company based on his games, practices and Clippers meetings. She organized when the private chef should come to prepare the family’s meals and even scheduled when everyone, including the family, needed to be out of the house so that Griffin could nap without disturbance prior to games. Sometimes this required waking the children from their own naps and driving around until Griffin had gotten his necessary rest 65. Cameron collaborated with the chef and Griffin’s nutritionist to ensure Griffin had the proper meals. This included planning meals based on his blood work indicating what nutrients he was lacking. Griffin preferred certain meals the night before a game, game day, and following a game. 13 COMPLAINT FOR DAMAGESA auewn 10 n 12 13 14 15 16 17 18. 19 20 21 2 4 25 26 27 28 Griffin notified Cameron about which foods his body did not process well, and Cameron was responsible for informing their chef about Griffin’ wishes and ensuring that they were carried out. ‘When Griffin was on the road for away games, Cameron planned his meals, snacks, smoothies, juices, and vitamins with their chef and personally delivered them to the Clippers practice facility before the team departed. 66. Cameron introduced Griffin to his physical therapist, essential personnel to an NBA. player. Under the watchful eye of his new physical therapist, Griffin’s recurring injury problems lessened and his on-court performance improved. A range of personal trainers were in and out of their hhome almost every day — and Cameron strengthened Griffin’s relationships with them, inviting them to join family meals and buying gifts for their children on special occasions. 67. Cameron frequently arranged to host Griffin’s teammates and their families at their home, including making playdates for their children. ‘These personal, family connections strengthened Griffin’s bonds with his teammates and allowed the organization to sce a different side of his personality rather than the hard-partying man-child Griffin had been prior to their cohabitation. Hosting teammates created opportunities for him to lead by example, eared him more respect as a leader, and portrayed Griffin as the future of the franchise, Teammates’ wives informed Cameron that their husbands thought Cameron’s influence was the best thing to happen to Griffin. 68. Cameron was also Griffin’s stylist. She put together his game day outfits and packed his clothing for him prior to the games, NBA players are well known for their fashion sense, often hiring professional stylists to dress them for pre-game appearances and post-game press conferences, which can open the doors for fashion collaborations with designers and spreads in fashion magazines. Cameron organized and arranged Griffin's clothing by outfit for Clippers road trips, dramatically improving his sense of style and increasing his potential career opportunities. 69. Cameron further advised Griffin regarding his endorsement deals based on her experience working in sports marketing. After each meeting with a potential endorser, Griffin and Cameron reviewed the offer and the contract, weighing the pros and cons, including whether it required too many appearances and travel, a commitment Griffin did not like to make, Cameron advised Griffin to negotiate more, creative input in his commercials since he was interested in starting his own 14 COMPLAINT FOR DAMAGESeo) eet) ee WW 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 production company. Griffin took Cameron’s advice and began to assist in the creation of his commercials with Kia and Redbull, a great opportunity to learn more about the production process and. to allow his personality to shine through in the commercials. The resulting 2015 Kia “Showdown” campaign, starring Griffin, won a Clio award, an esteemed international advertising award. In addition, for his shoe deal, Jordan Brand sent Griffin 10-15 shoe colors to choose from at the beginning of each season, and Cameron chose the colors for Griffin to wear. 70. Cameron supported Griffin in founding his production company by introducing him to a possible producticn partner, Ryan Kalil. Her instinct was right, and the two founded their successful production company, Mortal Media. 71. At the end of the 2016-2017 NBA season, Griffin opted out of his Clippers contract and became a free agent, allowing him to sign with any team in the NBA, Hoping at the time to re-sign Griffin, the Clippers relied on Cameron’s influence. Lawrence Frank contacted Cameron when the Clippers were putting together a show as part of their efforts to re-sign Griffin during his free agency. 72. Griffin relied so heavily on Cameron’s advice and opinion that he even asked her to come| into his meeting with the Clippers prior to making his final decision to re-sign with the team for five ‘years for approximately $173 million, It would be difficult to find another wife or partner who has been. so essential to her.husband’s NBA career. 73. Griffin knew Cameron’s endless support had changed his life and career, and he frequently referred to Cameron as “his rock.” As a result of her dedication to him and their family, Griffin’s career benefitted tremendously. Griffin’s family, agent, teammates, coaches, and Clippers ‘owners all credited Cameron and noted her positive impact on Griffin’s life and career. 74. Cameron attended every home game with family tickets provided by Griffin to support Griffin pursuant to the Agreement. Cameron and the children waited for Griffin after games in the Clippers’ family room. Following the games, Cameron rode home with Griffin, discussing his performance and team dynamics. Cameron would put the children to bed, and then stayed up with Griffin to analyze the game film. Using Cameron’s expertise as an NCAA basketball player, Griffin andl ‘Cameron would discuss what he should have done differently, including reading the defense on pick and| rolls, how to defend screens based on the player, ways to correct his shot if it was off that day, and other 15. COMPLAINT FOR DAMAGESee 10 ul 12 13, 14 15 16 7 18 19 20 2 2 2B 4 25 26 27 28 areas of improvement. 75. Griffin struggled to be viewed as a leader for the Clippers while Chris Paul was such a vocal presence in the locker room and the media — and was better known for his drive to win and dedication to both team building and family values. Cameron counselled Griffin to lead in his own way by setting a standard for hard work, 76. Cameron frequently advised Griffin on how to become a better communicator with his teammates and his coaches, including how to speak with them when issues would arise, ‘The relationship between Griffin and other teammates had become so toxic Rivers had to mediate disputes in private meetings with the players. Griffin did not know how to handle confrontations and would go silent when things did not go his way. To change that dynamic, Cameron would coach Griffin on how to communicate his issues. 77. Griffin's agents involved Cameron as an advisor to his career, and relied on her opinion and influence, When Griffin re-signed with the Clippers on June 30, 2017, Griffin’s agent, Sam Goldfeder (“SG”), texted Cameron: SG: You're a good and loving woman. I am so happy for your family. B belongs here. They wanted him the most. Enjoy this great time. ‘Cameron: First I want to thank you for being so loyal to Blake. It means mere than you would ever know! Your honestly [sic] and genuine kindness is one we will always always always be so grateful for. So thank you. This whole world is a little intense at times but you have been a great influence for Blake on more than just basketball so thank you for being that to him, [Ihe] had to take less to achieve his goal I was on board just thought he should be paid what he was worth and the other teams weren't doing that. ‘This is his team and I’m happy he’s getting everything he-always should. 1 think this is his best situation to be in...Building a team around him and the beginning of his prime ... I’m excited to see where this year goes and to see Blake take charge on a different level of his game. 1 think he’s at a good place to take a team under his wing. il SG: Your words mean so much to me. He is where he belongs, ‘The whiole “feel” has changed now. This finally is HIS team and rightly so. Thank you for letting me be a part of this joumey. 78. Even the NBA referees took note of Griffin’s growth as a person and player. Griffin noticeably argued less with the referees and kept his negative and impulsive emotions in check. An 16 COMPLAINT FOR DAMAGESRUN Caran 10 WW 12 13 14 15. 16 7 18 19 20 21 22 23 24 25 26 27 28 NBA referee personally told Cameron that Griffin's on-court attitude was better because of her. 79, April 14, 2017, the Los Angeles Times published a story entitled, “Fatherhood fueled transformation for Griffin began to receive better press coverage as a result of his new image. On or about Clippers’ Blake Griffin,” writing: Griffin ... acknowledg{ed] how there has been this inner peace because of his family and how it arrived simultaneously with the serenity he feels as a highly trained basketball player. “Now it’s like what kind of example am I leaving or setting for my son and ... when my daughter can actually know what’s going on? What type of éxample am I showing her about how she should expect to be treated by men and all those things? Like, that’s the biggest thing. I feel like I’m the same person. I like the same stuff, but I spend my time a little differently and I think a litte differently.” ‘There has been a calmness with Griffin this season, perhaps it being the natural evolution of turning 28 or maybe having endured so much turbulence. He doesn’t argue with the officials as much anymore, He moves on to the next play faster. Being at peace has allowed him to play at a premium level this season as the Clippers play the Utah Jazz.in Game 1 of the Wester Conference playoffs Saturday night at Staplés Center. “It’s like being comfortable with exactly who you are and what you aren't just as much as who you are,” Griffin said. “T think that’s where I found ‘my peace. Iam what Iam. At the end of the day, I know if I’m putting in the work and I’m doing things the right way and I’m trying to be the right type of person, that’s all I can ask for. ... That’s all you can ask for from. your friends, from your family.” “ist like everything last season made me take a step back and realize and be grateful for the people that I do have in my life,” Griffin said, “In a ‘way, you kind of have to go through something like that — not that you dop’thave to. But ... l always try to find a positive in everything. T guess that’s the positive I took away from all that stuff.” For four years as teammates, J.J. Redick has seen Griffin’s growth. “It's just a natural maturation that happens as you get older,” Redick said. “When your priorities become your friends and your family, I think that maturation process can happen a lot quicker. But he was way more mature than I was at his age. I just see a different person. He just seems 17 ‘COMPLAINT FOR DAMAGESCaer ann een 10 ML 12 1B 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 mote at peace.” “There’s not anything he can't do,” Minnesota Coach Tom Thibodeau said. “You can see he plays with a lot of poise. His skill set is unusual for a guy that size.” “He has improved his range when it comes to shooting the three-bal,” Phoenix forward Jared Dudley, a former teammate of Griffin, said. “But his post moves, he still does the pound, pound, spin over to his left shoulder for a hook shot. So I think that’s where he still has to develop. But overall, I think he has been consistent in these last three or four years.” “He's shooting the ball better every year,” Dallas Coach Carlisle said. “He doesn’t seem to hunt threes, but when he gets them late-clock, he flicks a large percentage of them in, He’s been one of my favorite players to watch because he’s just such a unique talent. His personality is captivating, even if he is a bit of a flopper.” 80. Cameron also cared for Griffin through his numerous injuries and setbacks, On January 23, 2016, Griffin,'after drinking too much, punched one of the Clippers’ equipment managers. Disaffected teammates tured on Griffin and leaked the incident to the media, Griffin called Cameron in tears when the story broke. As a result of negative press coverage and public outrage, Griffin was suspended from playing for four games. 81. Inaddition to the suspension, Griffin faced a lengthy layoff because he had broken his hhand in the process. Griffin’s first surgeries were unsuccessful and he had to have an additional operation on his hand two weeks later. Cameron took Griffin to every doctor appointment, waited in the hospital during surgery, greeted him when he woke up, and made sure he had all of his medications. Griffin was in such pain one night, Cameron went to the pharmacy twice in the middle of the night to get him more medication, 82. Griffin relied on Cameron when many of his teammates and their families were not supportive of him, Cameron encouraged Griffin to leam from his mistake. Griffin took Cameron’s advice and many in and around the NBA noticed how he used the incident to improve as a person, 83. Inor about April 2017, Griffin suffered yet another serious injury, requiring surgery to 18 ‘COMPLAINT FOR DAMAGESSe ce a a ul 12 1B 14 15 16 7 18. 19 20 a 22 23 24 25 26 2 28 repair the plantar plate of his right big toe. Griffin and Cameron met with several doctors in Los Angeles, but, on the advice of another athlete, Cameron and Griffin visited Dr. Robert Anderson in ‘North Carolina for another opinion. Cameron and their son Ford accompanied Griffin to North Carolina, leaving their young daughter Finley with Cameron’s parents. After examination, Dr. Anderson suggested immediate surgery. Griffin and Cameron decided together that Griffin would undergo surgery that same aftemioon. Cameron was treated as Griffin's spouse throughout this possibly career-altering injury. While Griffin was still under anesthesia following surgery, Dr. Anderson informed Cameron the injury was worse than expected once he began operating, and their decision to operate immediately was crucial. 84, Throughout the process, Cameron served as Griffin’s liaison to the Clippers. She arranged their return travel to Los Angeles and cared for Griffin on their flight home, along with their son, 85. Griffin relied on Cameron after each of his injuries to recover and return to the court. Cameron picked up his medications, recorded all of the medicine he took and when he took it, and ‘communicated with his doctors to alter his prescriptions to manage his fitness and medical regimens. In addition, Griffin continued to rely on Cameron for near-constant emotional and mental support. Cameron Sacrificed Her Career to Support Griffin and Their Family to Her Detriment 86. Anytime Cameron discussed her interest in resuming her professional career, Griffin discouraged it. He stressed that he “needed” Cameron available as a full-time mom, to run the household, and to support his NBA career, which she could not do if she was working. He did not want their children to be raised by a nanny or a working mother. He repeatedly reiterated she did not need he own career because everything that was his was hers, and he would provide her with everything she needed for the rest of her life. 87. Agaresult, Cameron rejected numerous career opportunities to keep her promise to devote her full time to Griffin's career and the domestic tasks for their family. Cameron’s former boss at TBWA\Chiat\Day asked Cameron to return to work for him several times after she quit in August 2013 to raise Ford. One of his offers was to join him in starting his own sports marketing firm, a position for which Cameron would have been uniquely suited. In addition to her former boss, rival 19 ‘COMPLAINT FOR DAMAGESaus wn oN 10 i 12 13 14 15 16 7 18 19 20 ai 23 24 25 26 2 28 marketing and advertising agencies offered Cameron positions to establish their sports marketing departments, Cameron passed on every offer. 88. Cameron similarly tured away all interior design opportunities pursuant to the Agreement, 89. Cameron relied on the Agreement to her detriment by refusing all business opportunities, Cameron’s reliance was reasonable and foreseeable, 90. Griffin suggested that when his career was over and their children were older, he would help her focus on her career goals. Cameron relied on those promises at the expense of her own career. 91. Inan email entitled “love letter” dated February 3, 2017, Griffin reiterated how thankful he was for all of the sacrifices Cameron had made for him and their family: brynnie, i figured the start of a long trip like this is a good time to finishing [sic] my love email. So after 27 rough drafts here itis ... jk i just wrote this which is why it’s a bunch of random thoughts but it’s my version of a love letter. if you asked me 10 years ago where i wanted to be in life it would have been right here where i am today (only missing a championship or 2 of 7) i obviously didn’t know you at the time but everything i have now i wanted then i just didn’t know it was going to be with you. the only problem was i didn’t have a plan on how i was going to get there which is somewhat of a problem for someone who likes to have a plan and then execute said plan, Somewhere along the way my priorities changes [sic], i still wanted the same things but the order of importance was skewed because I chose to numb the pain of losing, stress and pain etc etc by spending free time trying to forget about them instead of doing what i had always done. my first year in la was rough. as you know i don't do well mentally wl can't do the thing i've loved doing my entire life but you helped me probably more than you even know through that time. even when we weren't together i remember sometimes thinking i wish i could talk to you about something or ask your opinion on things and that hasn't changed to this day. since ford was born we've been through a lot and i've felt so many things and haven't always been clear on how i feel because i was hurt and angry ‘most of the time but i always loved you and i'm sorry for hurting you over the years it's something i still think about to this day and one of the few things i regret in life but i hope you understand i was hurt too (which was not your fault) and i didn’t know how to deal with it. as you know last year 20 COMPLAINT FOR DAMAGESBw RN Sow rxau n 12 13, 14 15 16 7 18 19 20 2 2 23 24 25 26 27 28 was easily the worst year of my life professionally but looking [sic] but i'm thankful that it ali happened because it showed me who people really are. some good, some bad but it all showed. since then i've realized several things: 1. you are the most loyal person i've ever been around 2, you make me better as a person everyday 3. i love you more than you know and i'm ‘working on being better at showing you i.e. this email 4. you are the person i want to be with for the rest of my life, i've never been truly happier in my life and i can't imagine having to go through life without you, cole, ford and finn by my side. i hope you know how much i appreciate how amazing of a mother you are and all of the sacrifices you make for our family. if you asked me today where i want to be 10 years from now it's again right where i am (plus a championship or 2 of 7) except this time i have a plan and you are a huge part of it and i'm going to see it all the way through. i can't wait to see where we end up after the next 10. ilove you, Blakey Griffin Breaches the Agreement 92. Cameron and Griffin planned their wedding for the weekend of July 28, 2017. The ‘wedding was postponed just a week before it was scheduled to take place because Griffin demanded Cameron enter into a prenuptial agreement that contradicted the Agreement, including denying her meaningful support and her share of their property. 93. Although the wedding was postponed, Cameron wanted to spend the weekend of July 28, 2017 with Griffin in Los Angeles. Instead, Griffin chose to leave his family and party in Las Vegas. Thereafter, Griffin and Cameron went to couple’s counseling, but, throughout August 2017, Cameron began to catch Griffin telling numerous lies about his whereabouts. Cameron then discovered, along with tabloid media readers, that Griffin had embarked on a high-profile affair with Jenner. 94. Griffin even failed to turn up at his daughter’s first birthday on September 12, 2017. Tabloid photographs showed he was, instead, in New York, with Jenner. 95. In or about August 2017, after cruelly embarrassing his family with his public fawning over Jenner, Griffin informed Cameron that he had no intention of continuing to live with her. Despite Cameron’s endless support for Griffin and their family, Griffin breached the Agreement and contractual obligations owed to Cameron, by denying Cameron full financial support commensurate with her 21 COMPLAINT FOR DAMAGESCaer auan 10 MW 12 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 lifestyle and her share of their joint property. 96. Cameron's friends rented their home to Cameron after Griffin kicked her out of their family home. Griffin paid only one month of rent. As of January 2018, however, that home is no longer] available to rent. While Griffin is continuing to earn millions from his NBA and endorsement deals, Cameron and theit children are homeless and cash-strapped. In Griffin’s absence, Cameron’s brother has had to provide Cameron and the children with financial support. FIRST CAUSE OF ACTION BREACH OF EXPRESS ORAL CONTRACT TO POOL EARNINGS AND ACCUMULATIONS| OF PROPERTY (Against Defendant Blake Griffin and Does 1-50) 97. Cameron re-alleges herein by this reference each and every allegation contained in Paragraphs | through 96, inclusive, of this Complaint as if set forth fully herein, 98. Inorabout July 2014, in the County of Los Angeles, State of California, while they were living together Cameron and Griffin entered into the Agreement. 99. Thereafter, from approximately July 2014 until approximately August 2017, Cameron and Griffin continued to live together accumulating as joint property earnings and income, and all property acquired:therewith, which resulted from all personal service, skill, effort and work that each of them, individually and jointly, had performed, expended or contributed during the time that they lived with each other. , 100. In or about August 2017, Griffin informed Cameron that he had no intention of continuing to live with Cameron, Thereafter, Cameron and Griffin ceased to live with each other, 101. Cameron has performed all conditions of the Agreement on her part to be performed, except to the extent Cameron is excused from performance due to the conduct of Griffin. In or about September 2017, Cameron requested Griffin to account for and divide equally all of the property described herein, both known and unknown to Cameron. 102. Beginning in or about August 2017, Griffin breached their Agreement and failed and refused, and continues to fail and refuse, to account for any of the property, or to divide any portion of the property in Griffin's control and possession with Cameron equally, or at all. 22 COMPLAINT FOR DAMAGESwr wn Secwrxa n 12 3 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 103. Cameron believes the true nature and extent of the joint property acquired and accumulated pursuant to the terms of the Agreement is extensive, including but not limited to, improvements to the Pacific Palisades Residence, Griffin’s NBA player contract and amendments thereto, endorsement payments, investments, motor vehicles, Mortal Media ‘ownership, and personal Property, 104. Asa proximate result of Griffin's failure and refusal to account to Cameron for any and all of the property in his possession, custody or control as herein alleged, Cameron has sustained damages in excess of the jurisdictional minimum of this court. SECOND CAUSE OF ACTION INTHE ALTERNATIVE, BREACH OF IMPLIED CONTRACT TO POOL EARNINGS AND ACCUMULATIONS OF PROPERTY AND IMPOSITION OF CONSTRUCTIVE TRUST (Against Defendant Blake Griffin and Does 1-50) 105. Cameron re-alleges herein by this reference each and every allegation contained in paragraphs 1 throygh 104, inclusive, of this Complaint as if set forth fully herein, 106. In or around July 2014, Cameron and Griffin commenced living together and held themselves out as a married couple and a family unit. 107. Griffin understood that Cameron would perform, expend or contribute such skills, effort, labors, and earnings on the condition that Griffin would combine his skill, efforts, labor, and eamings with those of Cameron and would share any property acquired as a result of those skills, efforts, labor, and earnings with Cameron. 108. As part of the contract implied by the conduct of the Parties, at the time Cameron and Griffin commenced living together, Cameron refused all career opportunities, and devoted her skills, efforts, labors, and earnings to Griffin, as described in detail throughout this Complaint. 109. Thereafter, Griffin manifested his assent to the condition on which Cameron performed, expended, and contributed her skills, efforts, labor, and earnings as herein described by accepting the skills, efforts, labor, and earnings of Cameron, and treating his skills, efforts, labor, and earnings as the joint property of both Cameron and Griffin, 110. In further confirmation of this implied understanding between Cameron and Griffin, 23 ‘COMPLAINT FOR DAMAGESa Caran 10 ul 12 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 Cameron and Griffin held themselves out socially, as well as otherwise, as husband and wifes they had children together; gave their daughter Finley only Griffin’s surname; combined their finances; and made joint decisions regarding their property. 111. Each party understood that, although one party may retain title, possession, custody, or control of the joint property, he or she would account for such property to the other party at the termination ofthe relationship, when either party manifested an intent to discontinue living together with the other party. 112. In or about August 2017, Griffin informed Cameron that he had no intention of continuing to live with Cameron. Thereafter, Cameron and Griffin ceased to live with each other. 113, Beginning in or about August 2017, Griffin breached the implied contract. Griffin failed and refused, and continues to fail and refuse, to account for any of the property, or to divide any portion of the property in Griffin's control and possession with Cameron equally, or at all. 114, Asa proximate result of Griffin’s failure and refusal to account to Cameron for any and all of the property in his possession, custody or control as herein alleged, Cameron has sustained damages in excess of the jurisdictional minimum of this court. 115. tthe time Cameron and Griffin commenced living together, and at all times during their relationship while they lived with each other, the most confidential relations existed between Cameron and Griffin, and Cameron reposed the greatest confidence and trust in Griffin, Cameron entrusted Griffin to account forall joint property acquired and accumulated through the Parties’ joint efforts. As a| result of this confidence reposed in Griffin, and of which Griffin was aware, Griffin did retain title, possession, custody, and control of the joint property herein described. 116, Asa result of the trust and confidence Cameron reposed in Griffin, Cameron relied on Griffin to perform the implied agreement with Cameron and to disclose fully all of the joint property of the Parties, its nature, extent, and value, and relied on Griffin to divide the Parties’ joint property ina manner that would result in a substantially equal division of the property. Griffin knew and was appraised of the trust and confidence so reposed in him by Cameron. 117, _Inesponse to Cameron’s request to account for all joint property acquired and accumulated through the joint efforts of Cameron and Griffin, Griffin violated the confidence Cameron 24 COMPLAINT FOR DAMAGESROE ee a 10 Wh 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 had placed in him and fraudulently repudiated the mutual understanding that had existed during the period in which Cameron and Griffin lived with each other by representing to Cameron that he did not have in his possession, custody, or control any property in which Cameron was entitled to share; by refusing, and continuing to refuse, to account for any property in his possession, custody, and control; and by refusing, and continuing to refuse, to disclose to Cameron the nature, extent, and value of the joint property. 118. Cameron believes the true nature and extent of the joint property acquired and accumulated during the period in which Cameron and Griffin lived with each other is extensive, including but not limited to, improvements to the Pacific Palisades Residence, Griffin's NBA player contract and amendments thereto, endorsement payments, investments, motor vehicles, Mortal Media ownership, and personal property, 119. Because of the violation of the confidence Cameron had placed in Griffin and of the repudiation of the mutual understanding between Cameron and Griffin respecting the treatment of all property acquired and accumulated through the skills, efforts, labor, and earnings of Cameron and Griffin, and each of them, Griffin should be declared by this court to be an involuntary trustee, holding one-half of the joint property, and the rents, issues, and profits therefrom in constructive trust for Cameron with the duty to convey the same to her forthwith. ‘THIRD CAUSE OF ACTION BREACH OF EXPRESS ORAL CONTRACT FOR SUPPORT (Against Defendant Blake Griffin and Does 1-50) 120. Cameron re-alleges herein by this reference each and every allegation contained in paragraphs | through 119, inclusive, of this Complaint as if set forth fully herein, 121. Inor about July 2014, in the County of Los Angeles, State of California, while they were living together, Cameron and Griffin entered into the Agreement. Among the material terms ‘unambiguously agreed to by the Parties were that Griffin would financially support Cameron commensurate with her lifestyle for the rest of her life and provide her with a home, 122. In or about August 2017, Griffin informed Cameron that he had no intention of continuing to live with Cameron. Thereafter, Cameron and Griffin ceased to live with each other. 25 COMPLAINT FOR DAMAGESSoca rau eun ul 12 13 14 15 16 7 18 19 20 2 2 23 24 25 26 27 28 123. In or about September 2017, Cameron requested Griffin to satisfy his obligation under the Agreement for support. Cameron has performed all conditions of the Agreement on her part to be performed, except to the extent Cameron is excused from performance due to the conduct of Griffin. 124, In response to Cameron’s request to provide support, Griffin failed and refused, and continues to fail and refuse, to perform the terms and conditions of the Agreement in that Griffin has failed to provide the agreed-upon support to Cameron, 125. Under the Agreement, there is now due and unpaid support payments to Cameron from Griffin under the Agreement necessary to pay living expenses commensurate with Cameron’s lifestyle from September 2017. 126. Griffin’s breach is a continuing one and payments due to Cameron from Griffin will continue to acerue, FOURTH CAUSE OF ACTION IN THE ALTERNATIVE, BREACH OF IMPLIED CONTRACT FOR SUPPORT. (Against Defendant Blake Griffin and Does 1-50) 127. Cameron re-alleges herein by this reference each and every allegation contained in paragraphs I through 126, inclusive, of this Complaint as if set forth fully herein. 128. Inor around July 2014, Cameron and Griffin commenced living together and held themselves out as,a married couple and a family unit, As part of the contract implied by the conduct of the Parties, Cameron did not pursue her career, refused all career opportunities, devoted her skills, efforts, labors, and earnings to Griffin which work, labor, and services primarily consisted of rearing their children, maintaining their home, personally assisting Griffin in his career, and performing numerous services for Griffin, as described in detail throughout this Complaint, In exchange, Griffin provided Cameron financial support commensurate with her lifestyle and a home. 129. In or about August 2017, Griffin informed Cameron that he had no intention of continuing to live with her, and Cameron and Griffin ceased to live with each other. 130. In or about September 2017, Cameron requested Griffin to satisfy his obligation under the implied agreement for support. 131. _In,response to Cameron’s request to provide support, Griffin failed and refused, and 26 COMPLAINT FOR DAMAGESrt 2 B 14 15 16 7 18. 19 20 2 22 23 24 25 26 27 28 continues to fail and refuse, to perform the terms and conditions of the implied agreement for support in that Griffin failed to provide the agreed-upon support to Cameron. 132. There is now due and unpaid support payments to Cameron from Griffin under the implied agreement necessary to pay living expenses commensurate with Cameron’s lifestyle from ‘September 2017. 133, Griffin's breach is continuing one and payments due to Cameron from Griffin will continue to accrue. FIFTH CAUSE OF ACTION IN THE ALTERNATIVE, QUANTUM MERUIT (Against Defendant Blake Griffin and Does 1-50) 134, Cameron re-alleges herein by this reference each and every allegation contained in paragraphs 1 through 132, inclusive, of this Complaint as if set forth fully herein. 135. During the period the Parties lived together, Cameron rendered work, labor, and services to Griffin which work, labor, and services primarily consisted of rearing their children, maintaining their home, personally assisting Griffin in his career, and performing numerous services for Griffin so that he could focus on improving his career and earn a max contract, as described in detail throughout this Complaint, including, but not limited to consulting regarding Griffin’s endorsement deals, personally assisting Griffin by keeping his schedule, engaging with Clippers management, corresponding with his, chef and nutritionist to ensure his health and ability to perform and play at the highest levels, styling his clothing for appearances, planning parties to strengthen his team bonds, nursing Griffin to health following numerous injuries and surgeries, and performing various services for Griffin. 136. Atall times mentioned herein, Cameron reasonably expected to be compensated for the above-described work, labor, and services to Griffin because the work, labor, and services performed are the type ordinarily performed for compensation, and Griffin on several occasions promised to make such] compensation. 137. Atal times herein mentioned, the reasonable value of the work, labor, and services rendered by Cameron was substantially less than Cameron would have earned in employment if she had not performed services for the benefit of Griffin. 27 COMPLAINT FOR DAMAGES5 Caran 10 MW 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 138. _Atall times herein mentioned, the reasonable value of the work, labor, and services rendered by Cameron exceeded the value of support Cameron received from Griffin during the term of their relationship. Further, the sizeable salary Cameron forwent to devote her time to the benefit of Griffin exceeded the value of support Cameron received from Griffin during the term of their relationship. 139. Griffin has not paid for Cameron’s services and there is now due and unpaid from Griffin to Cameron a sum according to proof at trial. SIXTH CAUSE OF ACTION DECLARATORY RELIEF (Against Defendant Blake Griffin and Does 1-50) 140, Cameron re-alleges herein by this reference each and every allegation contained in paragraphs | through 139, inclusive, of this Complaint as if set forth fully herein, 141. An actual controversy has arisen and now exists between Cameron, on the one hand, and Griffin, on the other hand, concerning their respective rights and obligations under the Agreement. Cameron contends that Griffin may not, directly or indirectly, quitclaim or transfer to any person any earnings and income, and all property acquired therewith, which resulted from all personal service, skill, effort, and work that each of them, thereafter, individually or jointly, performed, expended, or contributed during their relationship and while they lived with each other. Cameron is informed and believes, and on that basis alleges, that Griffin denies Cameron's contentions. 142. A judicial declaration is necessary and appropriate under the circumstances so that Cameron and Griffin may ascertain their rights, interests, obligations and duties with respect to foregoing and to avoid a multiplicity of actions. PRAYER FOR RELIEF WHEREFORE, Plaintiff Brynn Cameron prays for judgment against Defendant Blake Griffin and Doe Defendants 1-50 as follows: ON THE FIRST CAUSE OF ACTION 1. The court order Griffin to account to Cameron for all the joint property, earnings and income and all property acquired therewith, which resulted from all personal services, skills, effort, and 28 COMPLAINT FOR DAMAGESawn Cora 10 u 12 1B 14 15 16 17 18 19 20 2 23 24 25 26 27 28 work that Cameron and Griffin, and each of them, performed, expended, or contributed during the period of their relationship and while they lived with each other; 2. That on ascertaining the nature and extent of the property subject to the Agreement between the Parties, the court award Cameron damages in the amount of one-half the property; and 3. ‘That inthe alternative, if Cameron and Griffin are able to stipulate toa specific division of the property subject to the Agreement, the court order a division of the property pursuant to such a stipulation. ON THE SECOND CAUSE OF ACTION 1, The court order Griffin to account to Cameron for all the joint property, earnings and income and all property acquired therewith, which resulted from all personal services, skills, effort, and work that Cameron and Griffin, and each of them, performed, expended, or contributed during the period of their relationship and while they lived with each other; 2. That on ascertaining the nature and extent of the property subject to the implied agreement between the Parties, the court award Cameron damages in the amount of one-half the property and be compelled to transfer legal title and possession of one-half of that property and one-half the rents, issues, and profits therefrom to Cameron; and 3. Or, in the alternative, that the court ascertain the nature, extent, and value of the joint property and award Cameron damages for breach of contract in the amount of one- half of the value of ‘that property; 4. Or, that in the alternative, if Cameron and Griffin are able to stipulate to a specific. division of the property subject to the implied agreement, the court order a division of the property pursuant to such a stipulation. ON THE THIRD CAUSE OF ACTION 1. For damages in a sum according to proof at trial. ON THE FOURTH CAUSE OF ACTION 1. For damages in a sum according to proof at trial. ON THE FIFTH CAUSE OF ACTION 1. For damages in a sum according to proof at trial. 29 COMPLAINT FOR DAMAGES10 u 12 13, 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1, Cameron seeks a judicial determination of their rights and interests under the Agreement, i.e, that Griffin provide adequate support necessary to pay Cameron's reasonable general living expenses from September 2017 for the rest of her life; that Griffin provide Cameron with her own home} that Griffin may not, directly or indirectly quitelaim or transfer to any person any earnings and income, and all property acquired therewith, which resulted from all personal service, skill, effort, and work that each of them, thereafter, individually or jointly, performed, expended, or contributed during their relationship and while they lived with each other. ON ALL CAUSES OF ACTION 1. For costs of the suit herein incurred; 2. For prejudgment interest; and 3. For other such relief as the court deems proper. AJURY TRIAL IS DEMANDED. DATED: February 14, 2018 FREEDMAN? TAITELMAN, LLP ftephanie Crane Rowe /Attorneys for Plaintiff Brynn Cameron 30 COMPLAINT FOR DAMAGES