Kenneth Carey, et al. v. Jonathan Kirk, et al.
DueProcess Privacy JusticiabilityDoctri
Whether UMG and Interscope Records can be held liable for profiting from an illegal marketing scheme involving physical attacks by DaBaby
1. Are UMG and Interscope Records able to handsomely profit from their involvement and contributions to an illegal marketing scheme comprised from illegal physical attacks by Jonathan Kirk aka DaBaby that created viral media coverage and increased DaBaby’s socia l media following by the millions? 2. Should the District Court have dismissed UMG and Interscope Records Motion to Dismiss C ount for conspiracy when 1. Plaintiff’s provided video admissions by involved but now deceased coconspirator Cam Coldheart, 2. proof that Defendants hid and suppressed required contract language that would include UMG in the contract between Plaintiffs and DaBaby/Jonathan Kirk and expose their involvement in the agreement , 3. UMG blatantly ignoring their code of conduct requiring actions taken to 4. avoid hurting other pe ople over 16 times in nearly monthly periods and many more facts that support the Plaintiff’s cause of action for conspiracy. 3. Can a company trade name (Interscope Records) evade service and any lawsuit because it is designated as a division of a larger company, even though it is one of the most recognizable brands in the world, contracts under the brand name Interscope Records an d holds itself out to the public as a company? 4. Is UMG and Interscope Records subject to the long arm jurisdiction based on their involvement and profit from the contractual agreement in Miami, Florida area and owning a company that has an office in Florida and selling 3 likely millions of sales in digital streaming, concerts, merchandise, public appearances and otherwise in Florida and throughout the 11th Circuit ? 5. Should a civil theft count be dismissed when a person robbed (Kenneth Carey) of cash, phone and cards does not know the exact amount of cash that was stolen from him nor the exact amount of the value of data on his phone that contained contacts to hard to reach celebrity artists ? 6. Was beating Kenneth Carey to the ground by jumping him by Dababy and his entourage, pouring apple juice on him and saying it looked like he peed himself, robbing him of his possessions, dragging him across the street while pulling his pants off and exposin g his private parts to the world, while cars passed close by endangering them all, and then knocking Carey to the ground, all similar to a prior attack by Dababy, and on camera and published to millions around the world on TMZ, youtube, major media outlets and otherwise, constitute Intentional Infliction of Emotional Distress? 7. Was it improper when Defendant Kirk DaBaby had granted the Motion to Dismiss the Count for Promissory Estoppel based on the defense of a valid contract existing then testif ied in Trial Court that a valid contract did not exist? 8. Can the Trial Court have knowledge of a subpoena delivered to a third party witness and then not require them to appear to testify based on that subpoena being issued . 9. Can the Trial Court deny authentication and admissibility of security camera video footage obtained via subpoena duces tecum through the Court process when the Plaintiffs attempted to authenticate the video which they were in the contents of the video. 10. Can UMG and Interscope records completely avoid discovery and producing documents based on ignoring the discovery request timely submitted to them until the deadline? 11. Can UMG and Interscope avoid a timely scheduled deposition of a corporate representative because the scope of the deposition would be what they 4 considered too broad, which the scope was stated as “all knowledge relating to the Counts in the Complaint” ? 12. Can UMG and Interscope CEO’s avoid depositions based on the APEX doctrine when Plaintiffs presented statements that the CEO’s had specific knowledge about the attacks because the CEO’s were the only ones that could have overridden the code of conduct that required them to take action and sever relationships of people that hurt others ? A LIST OF ALL