MTB Entertainment Threatens Legal Action Against Planet Fitness For Racial Prejudice!
COMPLAINT FOR BREACH OF CONTRACT Plaintiff complains and for causes of action alleges as follows: FIRST CAUSE OF ACTION For Breach of Contract Against Member Agreement Due To Racial Prejudice
1619 Wilcox Ave #1124
Hollywood, Ca 90078
State Bar No: 000007
"In Pro Per as "Esquire""
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
Marcus Todd Brooks
BREACH OF CONTRACT
Plaintiff complains and for causes of action alleges as follows:
FIRST CAUSE OF ACTION
(For Breach of Contract Against Member Agreement Due To Racial Prejudice)
Planet Fitness, is, and at all times herein mentioned, was a Corporation organized and existing under the laws of the State of California with principle offices/gym located at, in the City of Los Angeles, County of Los Angeles.
Marcus Todd Brooks is ignorant of the true names and capacities of defendants sued herein, and therefore sues "Planet Fitness" these defendants by such fictitious names. Marcus Todd Brooks will amend this complaint to allege their true names and capacities when ascertained.
Marcus Todd Brooks is informed and believes and thereon alleges that, at all times herein mentioned, each of the defendants sued herein was the agent and employee of each of the remaining defendants and was at all times acting within the purpose and scope of such agency and employment.
On or about March 6th 2019, in the City of Los Angeles, County of Los Angeles, State of California, Plaintiff and defendant entered into a written agreement, a copy of which is attached hereto as Exhibit "A" and Exhibit "B" cancellation notice emailed to plaintiff made a part hereof. By the terms of said written agreement;
The consideration set forth in the agreement was the fair and reasonable.
Plaintiff has performed all conditions, covenants, and promises required by him on his part to be performed in accordance with the terms and conditions of the contract.
On or about March 6th, 2019 the defendant breached the said agreement by downgrading paid in full membership and terminating membership with racial bias with no proven cause.
By reason of defendant breach of said contract as herein alleged, the plaintiff has suffered damages in the sum of $ 5 billion.
By the terms of said written agreement and/or the law, the Plaintiff is entitled to recover reasonable attorney fees incurred in the enforcement of the provisions of the agreement and damages. By reason of the aforementioned breach of the defendant, the Plaintiff has been forced to secure the services of the legal firm of MTB ENTERTAINMENT to prosecute this lawsuit.
WHEREFORE, Marcus Todd Brooks pray judgment against defendant Planet Fitness and each of them, as follows:
For compensatory damages in the sum of $ 5 million;
For reasonable attorney fees according to proof;
For costs of suit herein incurred; and
For such other and further relief as the court may deem proper.
I, Marcus Todd Brooks, am a plaintiff in the above-entitled action. I have read the foregoing and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein alleged on information and belief, and as to those matters, I believe it to be true.
I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed at Compton, California.
Cosigner Authorization & Waiver
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