Flava Works vs. PLATINUM PLANNING GROUP, INC. D/b/a SIZZLE MIAMI and SIZZLE, LUIS MEDRANO and DWIGHT POWELL - Complaint and Exhibits

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

FLAVA WORKS, INC.,

Plaintiff, COMPLAINT

vs.

PLATINUM PLANNING GROUP, INC.
d/b/a SIZZLE MIAMI and SIZZLE, LUIS
MEDRANO and DWIGHT POWELL,

Defendants.
_______________________________________/

Plaintiff, Flava Works, Inc. (Flava Works), by and through undersigned counsel hereby
files this complaint against Defendants, Platinum Planning Group d/b/a Sizzle Miami (Sizzle),
Luis Medrano and Dwight Powell (Powell), and as grounds therefore states the following:
INTRODUCTION
1. This is an action by Flava Works to recover damages arising from infringement of
Plaintiffs copyrights and trademarks in its creative works by the Defendants.
2. Sizzle is owned and operated by Dwight Powell and Luis Medrano.
3. Defendants reproduced and distributed certain Plaintiff-owned works through its
website, www.sizzlemiami.com and www.sizzleshopping.com and through its hard-copy
publication of the Sizzle promotional booklet.
Case 1:11-cv-22817-KMM Document 1 Entered on FLSD Docket 08/05/2011 Page 1 of 13
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4. The Defendants actions were willful in nature, entitling the Plaintiff to enhanced
damages. The Plaintiff seeks statutory damages, actual damages, an award of its attorneys fees
and costs of suit, as well as injunctive relief.
JURISDICTION AND VENUE
5. This Court has subject matter jurisdiction pursuant to the Copyright Act 17 U.S.C.
101 et seq.
6. This Court has personal jurisdiction over the Defendant Sizzle, which has its
place of business at 3301 NE 1
st
Ave., Suite 1103, Miami, Florida 33137.
7. This Court has personal jurisdiction over the Defendant Dwight Powell, who
resides in Miami-Dade County.
8. This Court has personal jurisdiction over the Defendant Luis Medrano, who
resides in Miami-Dade County.
9. Venue is proper in this Court pursuant to 28 U.S.C. 1391(b), (c) and (d); and 28
U.S.C. 1400(a).
THE PARTIES
THE PLAINTIFF, FLAVA WORKS, INC.
10. Flava Works is a Florida Corporation with a mailing address of 2610 North
Miami Ave, Miami, Florida 33127.
11. Plaintiff Flava Works produces, markets, and distributes adult-oriented
audiovisual under registered trademarks, including photographs, DVDs, and through the
operation of websites and its magazine. On these websites, individuals purchase monthly
subscriptions to view Plaintiffs photographic works and audiovisual content. In addition,
individuals subscribe to Flava Men magazine, a Flava Works publication.
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12. Flava Men, a high-quality content magazine geared towards the gay community
and is only available to subscribers.
DEFENDANT PLATINUM PLANNING GROUP, INC. d/b/a SIZZLE
13. Sizzle does business as and operates the website www.sizzlemiami.com
14. Defendant Sizzle host the event, Sizzle Miami, which is geared towards the gay
community.
15. Plaintiff avers that each Defendant, individually, corporately, jointly and/or
severally, acted intentionally, knowingly, negligently or through willful blindness, as an agent, or
representative of each and every, all and singular, the other Defendants, and acted to further the
ends of the illegal and improper purposes alleged herein in a common course or scheme to
infringe on the Plaintiffs copyrighted intellectual property for profit and monetary gain.
DEFENDANT DWIGHT POWELL
16. On information and belief, Powell is the owner and operator of the website
www.sizzlemiami.com.
17. Powell is listed as the officer/director of Sizzle.

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DEFENDANT LUIS MEDRANO
19. On information and belief, Luis Medrano is the owner of Sizzle Miami. Exhibit
A.
STATEMENT OF FACTS
21. Plaintiff hosts an annual award show for those in the gay-adult industry.
22. Defendants host an annual Memorial Day Weekend Event in Miami catering to
the gay community.
23. The event is promoted on its website, e-mail advertising, and through its
publication. Exhibit B.
24. Defendants without authorizations used Plaintiffs copyrighted images in the
promotion of its events. Exhibit C.
25. Sizzle makes it money through the promotion of its event.
26. Additionally, Sizzles business model depends in part on the notability of those
whom attend its events. Exhibit D.
27. The Flava Works models whose images are used on Sizzles website, e-mail
blasts, and publication are the images of Baby Star, a well-known model and entertainer within
the industry. Exhibit E.
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blasts, and publication are the images of DeAngelo Jackson, a well-known model and entertainer
within the industry. Exhibit F.
blasts, and publication are the images of Matrix, a well-known model and entertainer within the
industry. Exhibit G.
blasts, and publication are the images of Xavier Vega, a well-known model and entertainer
within the industry. Exhibit H.
31. The images of the four models are copyrighted. Exhibit I.
32. The pictorial works at issue are valuable, and easily discernable as professionally
produced works. Plaintiff Flava Works created the works using the highest quality cameras,
lighting, and editing equipment.
33. Neither Defendants nor the individuals viewing the material pay anything to the
actual copyright owner of the material.
34. Plaintiff Flava Works discovered copyrighted material illegally shared on
Defendants website, e-mail advertising, and publication. See Exhibit C.
35. The exact number of times that the copyrighted material was shared on e-mail
blasts by Plaintiffs is unknown at this time. However, Plaintiff can establish that at least one e-
mail blast contained Plaintiffs copyrighted images. Exhibit B.
36. The exact number of times that the copyrighted material was shared in Defendants
published booklet by Plaintiffs and is unknown at this time. However, Plaintiff can establish that
at least one published booklet contained Plaintiffs copyrighted images. Exhibit J.
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37. Plaintiff has trademarks and/or common law trademarks on Flava Works, Flava
Men Thugboy, and PapiCock. Exhibit K.
38. Defendant infringed on Plaintiffs trademarks in order to increase its profits.
Exhibit L.
39. Defendants actively engaged in and promote its copyright and trademark
infringements. Each infringement act occurred on Defendants website, e-mail blasts, or
publication.
40. Plaintiff Flava Works discovered and documented that Defendants reproduced
and publicly displayed through its website, e-mail advertising, and publication multiple
unauthorized pictorial files copyrighted by and belonging to Plaintiff.
41. Defendants intentionally, knowingly, negligently, or through willful blindness
choose to avoid reasonable precautions to deter its copyright infringement on Defendants
website, e-mail advertising, and publication and/or perpetuated the infringements itself.
42. Defendants acts and omissions allow them to profit by their infringement while
imposing on copyright owners a monetary burden to monitor Defendants promotions of its
events without sufficient means to prevent continued and unabated infringement.
43. Prior to releasing its works into the market, Plaintiff Flava Works marks each
work with a copyright notice. Plaintiffs labels reflect its true business address and a statement
that it is conforming to federal law.
44. Plaintiff Flava Works prominently displays its copyright and trademark marks on
its website, publications, and films.
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45. Defendants infringements harmed and continue to harm Plaintiff Flava Works
and others legally deriving the benefits of Plaintiffs creative works. Defendants continued
infringements undermine Plaintiffs and other creative enterprises that produce pictorial works.
46. Plaintiff Flava Works seeks immediate redress, as follows:
a. A declaration that Defendants conduct in reproducing and distributing Plaintiffs
copyrighted works and trademarks without authorization willfully infringes
Plaintiff Flava Workss copyrights and trademarks;
b. A permanent injunction requiring Defendants employ reasonable methods and/or
technologies preventing or limiting infringement of Plaintiff Flava Works
copyrights and trademarks;
c. Statutory damages for Defendants past and present willful infringement, or actual
damages plus profits.
d. A seizure of all of the instrumentalities of the Defendants illegal acts.
FIRST CAUSE OF ACTION
Copyright Infringement 17 U.S.C. 101 Et. Seq.

47. Plaintiff repeats and incorporates by reference as if verbatim, each and every
paragraph previous to this section, inclusive.
48. Plaintiff Flava Works holds the copyright on each of the infringed works alleged
in this action.
49. At all pertinent times, Plaintiff Flava Works was the producer and registered
owner of pictorial works illegally and improperly reproduced and distributed by Defendants
through its websites, e-mails blasts, and publications.
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50. Defendants reproduced, copyrighted works by and through servers and/or other
hardware owned, operated, and/or controlled by Defendant www.sizzlemiami.com.
51. Defendants reproduced, copyrighted works by and through in a publication owned
and/or controlled by Defendant Sizzle.
52. Defendants reproduced, copyrighted works by and through electronic mail owned
and/or controlled by Defendant Sizzle.
53. Defendants reproductions and distributions of the works were done without
proper approval or authorization of Plaintiff.
54. Defendants knew or should have reasonably known they did not have permission
to exploit Plaintiff Flava Works works on its websites, e-mails blasts, and publications and
further knew or should have known their acts constituted copyright infringement.
55. Defendants knew or should have known that Plaintiff Flava Works are the
copyright owners of the works. Defendants made no attempts to get permission from the owner
or license holder of copyrighted works prior to pirating them.
56. Defendants engaged in intentional, knowing, negligent, or willfully blind conduct
sufficient to demonstrate they engaged actively in the improper collection and distribution of
Plaintiff Flava Works copyrighted works.
57. The quality and quantity of copyrighted images available to Internet users, e-mails
blasts, and publications increased the attractiveness of Defendant Sizzles services to its
customers, increased the number of participating members in its events, and increased its sales
revenue.
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58. Defendants conduct was willful within the meaning of 17 U.S.C. 101, et seq. At
a minimum, Defendants acted with willful blindness and reckless disregard of Plaintiff Flava
Works registered copyrights.
59. Because of their wrongful conduct, Defendants are liable to Plaintiff for copyright
infringement. Plaintiff suffers and will continue to suffer substantial losses, including, but not
limited to, damage to its business reputation and goodwill. See 17 U.S.C. 501.
60. The law permits Plaintiff to recover damages, including readily ascertainable
direct losses and all profits Defendants made by their wrongful conduct. 17 U.S.C. 504.
Alternatively, the law permits Plaintiff Flava Works to recover statutory damages. 17 U.S.C.
504(c).
61. Because of Defendants willful infringement, the law permits enhancement of the
allowable statutory damages. 17 U.S.C. 504(c)(2).
62. The law permits Plaintiff injunctive relief. 17 U.S.C. 502. Further, the law
permits a Court Order impounding any and all infringing materials. 17 U.S.C. 503.
63. Plaintiff Flava Works has no adequate remedy at law for Defendants wrongful
conduct, as follows:
a. Plaintiffs copyrights are unique and valuable property having no readily
determinable market value;
b. Defendants infringement harms Plaintiffs business reputation and goodwill such
that Plaintiff could not be made whole by any monetary award; and,
c. Defendants wrongful conduct and damages to Plaintiff are continuing and
unremitting.
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d. Plaintiff is entitled to preliminary and permanent injunctive relief prohibiting
further infringement of Plaintiffs copyrights; 17 U.S.C. 502.

SECOND CAUSE OF ACTION
Trademark Infringement 15 U.S.C. 1125
False Designations of Origin

64. Plaintiff is the holder of the following pending, federally registered, and/or
common law trademarks: Flava Men, Serial Number 76609587; Flava Works, Serial Number
85086562; Thugboy, Serial Numbers 77915525 and 77919166; PapiCock, Serial Numbers
77910877 and 77914926.
65. Plaintiffs trademarks are inherently distinctive.
66. The relevant market associates the Plaintiffs trademarks exclusively with the
Plaintiff.
67. Plaintiff includes its trademarks and logos on the packaging for its DVDs and in
frames for the videos that it produces. This identifies the works as those of the Plaintiff.
68. Plaintiff also includes its trademarks and logos on its websites, publications, and
e-mail blasts.
69. Defendants include the Plaintiffs logos and trademarks on his websites and
publications in its promotions of its events to the public.
70. Plaintiff has made, and continues to make, substantial investments of resources in
the production, marketing, and branding of its products sold and otherwise distributed under
these trademarks.
71. Plaintiff takes great care in creating the look and quality of the products sold
under its mark, including the production values inherent in the films themselves, but also
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including the packaging of its DVDs and the materials provided to consumers with the Plaintiffs
goods.
72. Plaintiff exercises a great degree of control and oversight in the production and
post-production stages of the creation and marketing of its products. This is to insure that all of
the Plaintiffs productions retain their distinctive character and quality, so as to maintain the
Plaintiff s reputation in the relevant marketplace.
73. Plaintiff has exercised the same degree of conscientiousness in hosting and
promoting the Blatino Awards. Plaintiffs event has been a success mostly due to the investment
he has made in its productions, websites, and publications.
74. Plaintiff has, at all times relevant hereto, taken care to enforce its trademarks and
to prevent third parties from infringing thereupon.
75. Plaintiff has, at all times relevant hereto, exercised significant control over the
technical quality of its goods and services, including but not limited to the Plaintiffs copyrighted
works, as well as the packaging, duplication, manufacture, and distribution thereof, in order to
maintain the overall quality of the goods bearing the Plaintiff s trademarks and to protect the
value of the relevant trademarks.
76. Defendants use of Plaintiffs mark on its websites and publication to promote an
event that it has and will continue to profit from constitutes an intentional and unlawful use of
the Plaintiffs trademarks.
77. This misuse constitutes a false designation of origin and is likely to cause
confusion, mistake, or to deceive as to the affiliation, connection, or sponsorship of Defendants
activities by Plaintiff.
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78. This misuse has caused the Plaintiffs customers, members of the relevant trade, and
other end users to suffer confusion, mistake, and/or to be deceived as to the origin of the event.
79. On information and belief, as a direct and proximate result of his conduct, Defendants
have realized and continues to realize profits and other benefits rightfully belonging to the Plaintiff.
80. Defendants has willfully engaged in, and is willfully engaging in, the acts complained
of in this complaint with malice, fraudulent intent, and in conscious disregard for the Plaintiffs
intellectual property rights and other legal rights.
81. The Plaintiff has suffered damages of an amount to be proven at trial.
82. Plaintiff has been damaged by the Defendant's conduct, continues to be damaged by
such conduct, and has no adequate remedy at law to compensate the Plaintiff for all of the possible
damages stemming from Defendants conduct.
83. As Defendants conduct was an intentional act, using the Plaintiffs federally registered
trademarks, the Plaintiff is entitled to treble damages, attorney's fees, and costs of suit.
84. Additionally, Defendants brazen and willful conduct in this case rises to the level of it
being an exceptional case, thus independently entitling the Plaintiff to an award of its attorneys
fees expended in order to bring this action.
WHEREFORE; PLAINTIFF PRAYS

A. That the Court issue a Permanent Injunction in accordance with the Order requested
above;
B. That the Defendants be required to pay Plaintiff s actual damages proximately resulting
from the Defendant's acts, or statutory damages for each violation, as the Plaintiff may
elect as a matter of right;
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C. That the Defendant be required to pay treble damages for his willful trademark
infringement;
D. That Defendant accounts for:
1. All gains, profits, and advantages of any kind derived by him by his aforementioned
and complained-of acts and business practices;
2. All gains, profits, and advantages derived by the infringement upon the Plaintiffs
copyrights, or such damages as this Court shall deem proper within the provisions of
the Copyright Act, up to $150,000 for each unlawful duplication and distribution of
the Plaintiffs works, which was intentionally and unlawfully infringed upon by the
Defendant; and
3. For statutory and/or exemplary damages, as awarded by this Court;
E. That Defendant pays to the Plaintiff its reasonable attorneys' fees pursuant to 17 U.S.C.
505 and 15 U.S.C. 11 17(a);
F. That Defendant pays the Plaintiff the costs of this action; and
G. For any additional and further relief which this Court deems to be just and proper.

Respectfully submitted,
By: /s/ Stacy-Ann Frater_______________
MIRTA DESIR, ESQ. (NEW YORK BAR 4805057)
mdesir@gmail.com
STACY-ANN FRATER, ESQ. 41021
frater.stacyann@gmail.com
P.O. Box 611214
Miami, Florida 33261
2610 North Miami Avenue
Miami, Florida 33127
Tel.: 800-357-0576
Fax: 305-597-0676

OJS 44 (Rev. 2/08)
CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided
by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating
the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.
I. (a) PLAINTIFFS DEFENDANTS
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
(c) Attorneys (Firm Name, Address, and Telephone Number)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT
LAND INVOLVED.
Attorneys (If Known)
(d) Check County Where Action Arose: MIAMI- DADE MONROE BROWARD PALM BEACH MARTIN ST. LUCIE INDIAN RIVER OKEECHOBEE
HIGHLANDS
II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an X in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant
(Indicate Citizenship of Parties in Item III)
of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6
Foreign Country
IV. NATURE OF SUIT (Place an X in One Box Only)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 610 Agriculture 422 Appeal 28 USC 158 400 State Reapportionment
120 Marine 310 Airplane 362 Personal Injury - 620 Other Food & Drug 423 Withdrawal 410 Antitrust
130 Miller Act 315 Airplane Product Med. Malpractice 625 Drug Related Seizure 28 USC 157 430 Banks and Banking
140 Negotiable Instrument Liability 365 Personal Injury - of Property 21 USC 881 450 Commerce
150 Recovery of Overpayment 320 Assault, Libel & Product Liability 630 Liquor Laws PROPERTY RIGHTS 460 Deportation
& Enforcement of Judgment Slander 368 Asbestos Personal 640 R.R. & Truck 820 Copyrights 470 Racketeer Influenced and
151 Medicare Act 330 Federal Employers Injury Product 650 Airline Regs. 830 Patent Corrupt Organizations
152 Recovery of Defaulted Liability Liability 660 Occupational 840 Trademark 480 Consumer Credit
Student Loans 340 Marine PERSONAL PROPERTY Safety/Health 490 Cable/Sat TV
(Excl. Veterans) 345 Marine Product 370 Other Fraud 690 Other 810 Selective Service
153 Recovery of Overpayment Liability 371 Truth in Lending LABOR SOCIAL SECURITY 850 Securities/Commodities/
Exchange of Veterans Benefits 350 Motor Vehicle 380 Other Personal 710 Fair Labor Standards 861 HIA (1395ff)
160 Stockholders Suits 355 Motor Vehicle Property Damage Act 862 Black Lung (923) 875 Customer Challenge
190 Other Contract Product Liability 385 Property Damage 720 Labor/Mgmt. Relations 863 DIWC/DIWW (405(g)) 12 USC 3410
195 Contract Product Liability 360 Other Personal Product Liability 730 Labor/Mgmt.Reporting 864 SSID Title XVI 890 Other Statutory Actions
196 Franchise Injury & Disclosure Act 865 RSI (405(g)) 891 Agricultural Acts
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 740 Railway Labor Act FEDERAL TAX SUITS 892 Economic Stabilization Act
210 Land Condemnation 441 Voting 510 Motions to Vacate 790 Other Labor Litigation 870 Taxes (U.S. Plaintiff 893 Environmental Matters
220 Foreclosure 442 Employment Sentence 791 Empl. Ret. Inc. Security
Act
or Defendant) 894 Energy Allocation Act
230 Rent Lease & Ejectment 443 Housing/
Accommodations
Habeas Corpus: 871 IRSThird Party
895 Freedom of Information Act
240 Torts to Land 530 General 26 USC 7609
245 Tort Product Liability 444 Welfare 535 Death Penalty IMMIGRATION 900 Appeal of Fee Determination
Under Equal Access to Justice
290 All Other Real Property
445 Amer. w/Disabilities -
Employment
540 Mandamus & Other
462 Naturalization
Application
446 Amer. w/Disabilities -

Other
550 Civil Rights
463 Habeas Corpus-Alien
Detainee
440 Other Civil Rights 555 Prison Condition
465 Other Immigration
Actions

950 Constitutionality of State
Statutes
V. ORIGIN
Transferred from
another district
(specify)
Appeal to District
Judge from
Magistrate
Judgment
(Place an X in One Box Only)
1 Original
Proceeding
2 Removed from
State Court
3 Re-filed-
(see VI below)
4 Reinstated or
Reopened
5 6 Multidistrict
Litigation
7
VI. RELATED/RE-FILED
CASE(S).
a) Re-filed Case YES NO b) Related Cases YES NO
(See instructions
second page):
JUDGE DOCKET NUMBER
VII. CAUSE OF ACTION
Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless
diversity):
LENGTH OF TRIAL via ______ days estimated (for both sides to try entire case)
VIII. REQUESTED IN
COMPLAINT:
CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23
DEMAND $ CHECK YES only if demanded in complaint:
JURY DEMAND: Yes No
ABOVE INFORMATION IS TRUE & CORRECT TO
THE BEST OF MY KNOWLEDGE
SIGNATURE OF ATTORNEY OF RECORD DATE
FOR OFFICE USE ONLY
AMOUNT RECEIPT # IFP
FLAVA WORKS, INC.
DADE COUNTY, FL
THE FRATER FIRM
P.O. BOX 611214
MIAMI, FLORIDA 33261
800-357-0576
PLATINUM PLANNING GROUP, INC. d/b/a SIZZLE MIAMI
AND SIZZLE, LUIS MEDRANO AND DWIGHT POWELL
DADE COUNTY, FL
500,000.00
HON. JOSE MARTINEZ

3
August 2, 2011
Case 1:11-cv-22817-KMM Document 1-1 Entered on FLSD Docket 08/05/2011 Page 1 of 2
JS 44 Reverse (Rev. 02/08)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use
of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint
filed. The attorney filing a case should complete the form as follows:
I. (a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use only
the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then the official, giving
both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the time
of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land condemnation cases,
the county of residence of the defendant is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section (see attachment).
(d) Choose one County where Action Arose.
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.C.P., which requires that jurisdictions be shown in pleadings. Place an X in one
of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
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Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment to the
Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and box
1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the citizenship of the
different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this section
for each principal party.
IV. Nature of Suit. Place an X in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is sufficient
to enable the deputy clerk or the statistical clerks in the Administrative Office to determine the nature of suit. If the cause fits more than one nature of suit, select
the most definitive.
V. Origin. Place an X in one of the seven boxes.
Original Proceedings. (1) Cases which originate in the United States District Courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. When the petition
for removal is granted, check this box.
Refiled (3) Attach copy of Order for Dismissal of Previous case. Also complete VI.
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litigation transfers.
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is checked, do not check (5) above.
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VI. Related/Refiled Cases. This section of the JS 44 is used to reference related pending cases or re-filed cases. Insert the docket numbers and the corresponding
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VII. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional statutes
unless diversity. Example: U.S. Civil Statute: 47 USC 553
Brief Description: Unauthorized reception of cable service
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Demand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
Date and Attorney Signature. Date and sign the civil cover sheet.

CASE NO.:

FLAVA WORKS, INC.,

Plaintiff,

vs.

PLATINUM PLANNING GROUP, INC.,
d/b/a SIZZLE MIAMI and/or SIZZLE,
LUIS MEDRANO and DWIGHT POWELL,

Defendants.
_______________________________________/

SUMMONS

THE STATE OF FLORIDA:
To Each Sheriff of the State:

YOU ARE COMMANDED to serve this summons and a copy of the complaint or petition in this action on
defendant(s): Platinum Planning Group, Inc. d/b/a Sizzle Miami and/or Sizzle, by serving its Registered Agent:
Marlon A. Hill, Esq., at 201 S. BISCAYNE BLVD., 28TH FLOOR, MIAMI, FL 33131.

Each defendant is required to serve written defenses to the complaint or petition on Stacy-Ann Frater and/or Mirta
Desir, plaintiffs attorneys, whose address is 2610 North Miami Ave., Miami, FL 33127 within 20 days after
service of this summons on that defendant, exclusive of the day of service, and to file the original of the defenses
with the clerk of this court either before service on plaintiffs attorney or immediately thereafter. If a defendant fails
to do so, a default will be entered against that defendant for the relief demanded in the complaint or petition.

DATED on ____________________

CLERK OF COURT

By: _________________________
As Deputy Clerk

Except when suit is brought pursuant to section 768.28, Florida Statutes, if the State of Florida, one of its agencies,
or one of its officials or employees sued in his or her official capacity is a defendant, the time to be inserted as to it is
40 days. When suit is brought pursuant to section 768.28, Florida Statutes, the time to be inserted is 30 days.

IMPORTANT
A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written
response to the attached complaint with the clerk of this court. A phone call will not protect you. Your written
response, including the case number given above and the names of the parties, must be filed if you want the court to
hear your side of the case. If you do not file your response on time, you may lose the case, and your wages, money,
and property may thereafter be taken without further warning from the court. There are other legal requirements.
You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral
service or a legal aid office (listed in the phone book).
If you choose to file a written response yourself, at the same time you file your written response to the court you
must also mail or take a copy of your written response to the Plaintiff/Plaintiffs Attorney named below.
IMPORTANTE
Usted ha sido demandado legalmente. Tiene 20 dias, contados a partir del recibo de esta notificacion, para contestar
la demanda adjunta, por escrito, y presentarla ante este tribunal. Una llamada telefonica no lo protegera. Si usted
desea que el tribunal considere su defensa, debe presentar su respuesta por escrito, incluyendo el numero del caso y
los nombres de las partes interesadas. Si usted no contesta la demanda a tiempo, pudiese perder el caso y podria ser
despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen otros
requisitos legales. Si lo desea, puede usted consultar a un abogado inmediatamente. Si no conoce a un abogado,
puede llamar a una de las oficinas de asistencia legal que aparecen en la guia telefonica.
Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal, debera
usted enviar por correo o entregar una copia de su respuesta a la persona denominada abajo como
Plaintiff/Plaintiffs Attorney (Demandante o Abogado del Demandante).
IMPORTANT
Des poursuites judiciares ont ete entreprises contre vous. Vous avez 20 jours consecutifs a partir de la date de
lassignation de cette citation pour deposer une reponse ecrite a la plainte ci-jointe aupres de ce tribunal. Un simple
coup de telephone est insuffisant pour vous proteger. Vous etes obliges de deposer votre reponse ecrite, avec
mention du numero de dossier ci-dessus et du nom des parties nommees ici, si vous souhaitez que le tribunal entende
votre cause. Si vous ne deposez pas votre reponse ecrite dans le relai requis, vous risquez de perdre la cause ainsi que
votre salaire, votre argent, et vos biens peuvent etre saisis par la suite, sans aucun preavis ulterieur du tribunal. Il y a
dautres obligations juridiques et vous pouvez requerir les services immediats dun avocat. Si vous ne connaissez pas
davocat, vous pourriez telephoner a un service de reference davocats ou a un bureau dassistance juridique
(figurant a lannuaire de telephones).
Si vous choisissez de deposer vous-meme une reponse ecrite, il vous faudra egalement, en meme temps que cette
formalite, faire parvenir ou expedier une copie de votre reponse ecrite au Plaintiff/Plaintiffs Attorney (Plaignant
ou a son avocat) nomme ci-dessous.

/s/ Stacy-Ann Frater____________________
Printed: Mirta Desir (New York Bar 4805057)
Attorney for Flava Works, Inc.
Address: 2610 North Miami Ave.
Miami, FL 33127
Stacy-Ann Frater, Local Counsel of Record
Florida Bar No.: 41021


CASE NO.:

FLAVA WORKS, INC.,

Plaintiff,

vs.


Defendants.
_______________________________________/

SUMMONS


defendant(s): Dwight Powell, 3301 N.E. 1
st
Avenue, Suite 1103, Miami, Florida 33137.

Each defendant is required to serve written defenses to the complaint or petition on Stacy-Ann Fraer and/or Mirta
Desir, plaintiffs attorney, whose address is 2610 North Miami Ave., Miami, FL 33127 within 20 days after

DATED on ____________________

CLERK OF COURTS

By: _________________________
As Deputy Clerk


IMPORTANT
and prop-erty may thereafter be taken without further warning from the court. There are other legal requirements.
IMPORTANTE
IMPORTANT

/s/ Stacy-Ann Frater___________
Printed: Mirta Desir
Stacy-Ann Frater (41021)
Attorneys for Flava Works, Inc.
Miami, FL 33127


CASE NO.:

FLAVA WORKS, INC.,

Plaintiff,

vs.


Defendants.
_______________________________________/

SUMMONS


defendant(s): Luis Medrano, c/o Sizzle Miami at 3301 N.E. 1
st
Avenue, Suite 1103, Miami, Florida 33137.

Each defendant is required to serve written defenses to the complaint or petition on Stacy-Ann Fraer and/or Mirta
Desir, plaintiffs attorney, whose address is 2610 North Miami Ave., Miami, FL 33127 within 20 days after

DATED on ____________________

CLERK OF COURTS

By: _________________________
As Deputy Clerk


IMPORTANT
and prop-erty may thereafter be taken without further warning from the court. There are other legal requirements.
IMPORTANTE
IMPORTANT

/s/ Stacy-Ann Frater______________
Printed: Mirta Desir
Stacy-Ann Frater (41021)
Attorneys for Flava Works, Inc.
Miami, FL 33127

EXHIBIT A - 1 Case 1:11-cv-22817-KMM Document 1-5 Entered on FLSD Docket 08/05/2011 Page 1 of 14
EXHIBIT B - 1
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EXHIBIT D - 1 Case 1:11-cv-22817-KMM Document 1-5 Entered on FLSD Docket 08/05/2011 Page 11 of 14
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EXHIBIT E
EXHIBIT F
EXHIBIT G - 1
EXHIBIT G - 2
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H
Copyright Catalog (1978 to present)
Search Request: Left Anchored Name = flava works
Search Results: Displaying 18 of 51 entries
FlavaMen Magazine.
Type of Work: Serial
Registration Number / Date: TX0007220991 / 2010-08-04
Application Title: FlavaMen Magazine
Title: FlavaMen Magazine. [Published: 2008-01-01. Issue: vol. 6, no. 2, Summer 2010]
Serial Publication Year: 2008
Frequency: Quarterly.
Copyright Claimant: Flava Works, Inc. Address: 2610 N Miami Ave, Suite B, Miami, FL, 33127, United
States.
Nation of First Publication: United States
Authorship on Application: Flava Works, Inc., employer for hire; Domicile: United States; Citizenship: United
States. Authorship: collective work which may include text, editing, compilation, and
contribution(s) in which copyright has been transferred to the claimant.
Issues Registered: vol. 6, no. 2, Summer 2010. Created 2008; Pub. 2008-01-01. Reg. 2010-08-04;
TX0007220991
Rights and Permissions: Phillip Bleicher, Flava Works, Inc., 2610 N Miami Ave, Suite B, Miami, FL, 33127,
United States, (305) 438-9450, support@flavaworks.com
Names: Flava Works, Inc.
Save, Print and Email (Help Page)
Select Download Format
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Contact Us | Request Copies | Get a Search Estimate | Frequently Asked Questions (FAQs) about Copyright |
Copyright Office Home Page | Library of Congress Home Page
WebVoyage Record View 1 http://cocatalog.loc.gov/cgi-bin/Pwebrecon.cgi?v1=18&ti=1,18&Search...
1 of 1 2/16/2011 4:12 PM
EXHIBIT I - 1
FlavaMen Magazine.
Title: FlavaMen Magazine. [Published: 2009-04-01. Issue: vol. 5, no. 1, Spring 2009]
Copyright Claimant: Flava Works, Inc. Address: 2610 N Miami Ave, Suite B, Miami, FL 33127, United
States.
Issues Registered: vol. 5, no. 1, Spring 2009. Created 2008; Pub. 2009-04-01. Regarding title
information: On copy: No. 1. Reg. 2010-04-26; TX0007145781
Copyright Note: Regarding title information: On copy: No. 1.
1 of 2 2/16/2011 4:13 PM
EXHIBIT I - 2
Search Request: Left Anchored Title = flavalife
FlavaLife : Black & Latino gay travel & entertainment guide.
Title: FlavaLife : Black & Latino gay travel & entertainment guide.
ISSN: 1557-2668
Description: print material.
Frequency: Bimonthly.
Description based on: Vol. 1, issue 2, Nov./Dec. 2005.
Copyright Claimant: Flava Works, Inc.
Issues Registered: v. 1, issue 2, Nov-Dec05. Created 2005; Pub. 2005-11-01; Reg. 2006-02-14;
TX0006343508
WebVoyage Record View 1 http://cocatalog.loc.gov/cgi-bin/Pwebrecon.cgi?v1=2&ti=1,2&Search_Ar...
1 of 1 2/16/2011 3:35 PM
EXHIBIT I - 3
FlavaMen Magazine.
Title: FlavaMen Magazine. [Published: 2009-01-01. Issue: vol. 5, no. 1, Winter 2009]
States.
Issues Registered: vol. 5, no. 1, Winter 2009. Created 2008; Pub. 2009-01-01. Regarding title
1 of 2 2/16/2011 4:09 PM
EXHIBIT I - 4
FlavaMen Magazine.
Title: FlavaMen Magazine. [Published: 2009-04-01. Issue: vol. 5, no. 1, Spring 2009]
States.
Issues Registered: vol. 5, no. 1, Spring 2009. Created 2008; Pub. 2009-04-01. Regarding title
1 of 2 2/16/2011 4:13 PM
EXHIBIT I - 5
Search Request: Left Anchored Title = flavalife
FlavaLife : Black & Latino gay travel & entertainment guide.
Title: FlavaLife : Black & Latino gay travel & entertainment guide.
ISSN: 1557-2668
Description: print material.
Frequency: Bimonthly.
Description based on: Vol. 1, issue 2, Nov./Dec. 2005.
Copyright Claimant: Flava Works, Inc.
Issues Registered: v. 1, issue 2, Nov-Dec05. Created 2005; Pub. 2005-11-01; Reg. 2006-02-14;
TX0006343508
WebVoyage Record View 1 http://cocatalog.loc.gov/cgi-bin/Pwebrecon.cgi?v1=2&ti=1,2&Search_Ar...
1 of 1 2/16/2011 3:35 PM
EXHIBIT I - 6
Search Request: Left Anchored Name = lukebaby
Flava Men 2005 calendar
Type of Work: Text
Title: Flava Men 2005 calendar
Copyright Claimant: Lukebaby Productions, Inc.
Date of Creation: 2004
Date of Publication: 2004-09-01
Names: Lukebaby Productions, Inc.
WebVoyage Record View 1 http://cocatalog.loc.gov/cgi-bin/Pwebrecon.cgi?Search_Arg=lukebaby&S...
1 of 1 2/16/2011 3:37 PM
EXHIBIT I - 7
FlavaMen Magazine.
Title: FlavaMen Magazine. [Published: 2009-01-01. Issue: vol. 5, no. 1, Winter 2009]
States.
Issues Registered: vol. 5, no. 1, Winter 2009. Created 2008; Pub. 2009-01-01. Regarding title
1 of 2 2/16/2011 4:09 PM
EXHIBIT I - 8
United States Patent and Trademark Office
Home|Site Index|Search|FAQ|Glossary|Guides|Contacts|eBusiness|eBiz alerts|News|Help
Trademarks > Trademark Electronic Search System (TESS)
TESS was last updated on Fri Oct 8 04:06:29 EDT 2010
Please logout when you are done to release system resources allocated for you.
List At: OR to record:
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Word Mark FLAVA WORKS
Goods and
Services
IC 009. US 021 023 026 036 038. G & S: Digital media, namely, pre-recorded CDs, video tapes, laser
disks, DVDs, high definition digital disks, downloadable video recordings and streaming video featuring
men's lifestyles and adult entertainment. FIRST USE: 20040101. FIRST USE IN COMMERCE: 20040101
Standard
Characters
Claimed
Mark Drawing
Code
(4) STANDARD CHARACTER MARK
Serial Number 85086562
Filing Date July 16, 2010
Current Filing
Basis
1A
Original Filing
Basis
1A
Owner (APPLICANT) Flava Works, Inc. CORPORATION FLORIDA 2610 N. Miami Ave. Miami FLORIDA 33127
Type of Mark TRADEMARK
Register PRINCIPAL
Live/Dead
Indicator
LIVE
Trademark Electronic Search System (TESS) http://tess2.uspto.gov/bin/showfield?f=doc&state=4005:q7bj9e.10.1
1 of 2 10/8/2010 4:40 PM
EXHIBIT K - 1
TESS was last updated on Thu Oct 7 04:05:47 EDT 2010
Word Mark FLAVA WORKS
Goods and
Services
IC 009. US 021 023 026 036 038. G & S: Digital media, namely, pre-recorded CDs, video tapes, laser
disks, DVDs, high definition digital disks, downloadable video recordings and streaming video featuring
Standard
Characters
Claimed
Mark Drawing
Code
Filing Date July 16, 2010
Current Filing
Basis
1A
Original Filing
Basis
1A
Owner (APPLICANT) Flava Works, Inc. CORPORATION FLORIDA 2610 N. Miami Ave. Miami FLORIDA 33127
Register PRINCIPAL
Live/Dead
Indicator
LIVE
Trademark Electronic Search System (TESS) http://tess2.uspto.gov/bin/showfield?f=doc&state=4009:lamq6s.8.1
1 of 2 10/8/2010 1:09 AM
EXHIBIT K - 2
Word Mark PAPICOCK.COM
Goods and
Services
IC 009. US 021 023 026 036 038. G & S: Digital media, namely, a series of pre-recorded CDs, video tapes,
laser disks, DVDs, high definition digital disks, downloadable video recordings and streaming video featuring
Mark Drawing
Code
(3) DESIGN PLUS WORDS, LETTERS, AND/OR NUMBERS
Design
Search Code
02.11.25 - Blood vessels, human; Brain, human; Buttocks, human; Human, other parts of the body; Intestines,
human; Lungs, human; Nerves, human; Nose, human; Spine, human; Tongue, human
Filing Date January 19, 2010
Current Filing
Basis
1A
Original Filing
Basis
1A
Owner (APPLICANT) Flava Works, Inc. CORPORATION FLORIDA 2610 N. Miami Ave Miami FLORIDA 33127
Disclaimer NO CLAIM IS MADE TO THE EXCLUSIVE RIGHT TO USE "PAPI OR .COM" APART FROM THE MARK AS
SHOWN
Description of
Mark
The color(s) yellow and red is/are claimed as a feature of the mark. The mark consists of The mark consists of
a stylized drawing of a red penis over which the word PAPICOCK.COM is displayed made up of red letters that
have a yellow outline.
Register PRINCIPAL
Live/Dead
Indicator
LIVE
Trademark Electronic Search System (TESS) http://tess2.uspto.gov/bin/showfield?f=doc&state=4007:hccui0.3.1
1 of 2 10/8/2010 12:57 AM
EXHIBIT K - 3
TESS was last updated on Fri Oct 8 04:06:29 EDT 2010
Word Mark PAPICOCK
Goods and
Services
Standard
Characters
Claimed
Mark Drawing
Code
Current Filing
Basis
1A
Original Filing
Basis
1A
Disclaimer NO CLAIM IS MADE TO THE EXCLUSIVE RIGHT TO USE "PAPI" APART FROM THE MARK AS
SHOWN
Register PRINCIPAL
Live/Dead
Indicator
LIVE
Trademark Electronic Search System (TESS) http://tess2.uspto.gov/bin/showfield?f=doc&state=4005:q7bj9e.10.24
1 of 2 10/8/2010 4:41 PM
EXHIBIT K - 4
Word Mark THUGBOY
Goods and
Services
Mark Drawing
Code
(3) DESIGN PLUS WORDS, LETTERS, AND/OR NUMBERS
Design Search
Code
02.11.07 - Arms; Fingers; Hands; Human hands, fingers, arms
Current Filing
Basis
1A
Original Filing
Basis
1A
Published for
Opposition
June 1, 2010
Description of
Mark
The color(s) brown, white and light brown is/are claimed as a feature of the mark. The mark consists of the
word "THUGBOY" written in graffiti style letters that are brown with a white outline over a sideways clenched
right fist design outlined in black, containing two shades of light brown and a white thumbnail.
Register PRINCIPAL
Live/Dead
Indicator
LIVE
1 of 2 10/8/2010 12:57 AM
EXHIBIT K - 5
Word Mark THUGBOY
Goods and
Services
Standard
Characters
Claimed
Mark Drawing
Code
Current Filing
Basis
1A
Original Filing
Basis
1A
Published for
Opposition
June 1, 2010
Register PRINCIPAL
Live/Dead
Indicator
LIVE
1 of 2 10/8/2010 12:57 AM
EXHIBIT K - 6
TESS was last updated on Thu Sep 23 04:06:28 EDT 2010
Word Mark FLAVA MEN
Goods and Services IC 016. US 002 005 022 023 029 037 038 050. G & S: Monthly men's entertainment magazine
featuring pictures and text. FIRST USE: 20040601. FIRST USE IN COMMERCE: 20040801
Standard Characters
Claimed
Mark Drawing Code (4) STANDARD CHARACTER MARK
Filing Date August 30, 2004
Current Filing Basis 1A
Original Filing Basis 1A
Published for
Opposition
September 20, 2005
Registration Number 3025813
Registration Date December 13, 2005
Owner (REGISTRANT) LUKEBABY PRODUCTIONS, INC. CORPORATION ILLINOIS 40 East Chicago
Street, Suite 162 Chicago ILLINOIS 60611
(LAST LISTED OWNER) FLAVA WORKS, INC. CORPORATION FLORIDA 2610 NORTH MIAMI
AVE. MIAMI FLORIDA 331274438
Assignment
Recorded
ASSIGNMENT RECORDED
Attorney of Record Havona Madama
Disclaimer NO CLAIM IS MADE TO THE EXCLUSIVE RIGHT TO USE "MEN" APART FROM THE MARK AS
SHOWN
Register PRINCIPAL
Live/Dead Indicator LIVE
Trademark Electronic Search System (TESS) http://tess2.uspto.gov/bin/showfield?f=doc&state=4010:2mdmk8.3.1
1 of 2 9/24/2010 2:01 AM
EXHIBIT K - 7
Thursday May 26th - Tuesday May 31st
EXHIBIT L - 1
Founded in 2002, Sizzle Miami is now the nations most ex-
citing and celebrated gay event during the Memorial Day
weekenc. Fc( fve {5) ccy: Leinnin cn Ihu(:ccy. Mcy 2lh.
party seekers from around the world will convene in sunny
Miami, Florida celebrating life, pride & liberty.
Why Miami? Well Miami is unlike any other city in the United
States. Its a city in the making, unpredictable, everchang-
ing, and simultaneously laid-back. Residents and tourists alike
consider Miami a lush, exotic paradise and smorgasbord of
:ly|e. :uL:lcnce. cnc fc(e. Fu(lhe(mc(e. Micmi hc: p(cven lc
be extremely open and accepting of all cultures,
ethnicity and sexual orientations.
Attendees experience the pulsating nightlife and beaches of
Micmi f(cm cu:k li| ccwn. Ihey :wi(| c(cunc |cke:. wcle(wcy:.
inlets, harbors, marinas and the historic Miami River. Miami is
c f(c(cnl :picy Lcui||cLci::e lhcl ci:ccve( cnc :cvc(. Ihe
Paddle, sail, visit museums, shop i style, rent a convertible,
drop the top, clip on sunglasses, be a celebrity and live life
Miami-style.
Our friendly residents of south Florida invite you to be a part
of Sizzle 2011, the largest African-American and Latino gay
event to hit the Southeast coast.
Each year Sizzle Miami partners with local HIV/AIDS agen-
cies. In the United States, the impact of HIV and AIDS in the
African-American and Latino communities is devastating.
You may know that HIV/ AIDS is the second leading cause of
ceclh cmcn ccu|l: 25-44.
C
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EXHIBIT L - 2
2,000
4.000
.000
8,000
10,000
12,000
14.000
1.000
18,000
20,000
0
SEP OCT NOV DEC JAN FEB MAR APR MAY JUN-AUG
ATTENDANCE {Men-8)
Sizz|e 2003................................... .500......Feek Nihl /llenccnce{Sclu(ccy)...............................1.500
Sizz|e 2004................................... .000......Feek Nihl /llenccnce{Sclu(ccy)...............................2.315
Sizz|e 2005................................. 10.000......Feek Nihl /llenccnce{Sclu(ccy)...............................2.700
Sizz|e 2008..................................15.500......Feek Nihl /llenccnce{Sclu(ccy)...............................5.500
LINEUP OF EVENTS
Sizz|e feclu(e: 5 ccy: cf hcl :exy ccy cnc nihl-lime
evenl:. Ihe(e c(e c|:c ccy/ evenin evenl: cnc
they are:
Fcc| pc(ly
8ecch pc(ly
8ccl pc(ly
8c(Lecue
E|ecnl cinne(/ jczz evenl
Sizz|in nihl evenl:
Ccmecy Shcw
Fi|m Se(ie:
HlV /wc(ene:: & F(evenlicn
Ihe(e c(e 5 nihl evenl: Leinnin cn Ihu(:ccy Mcy
2lh lh(cuh Iue:ccy Mcy 31:l cl vc(icu: |ccclicn:
in Miami.
2011 NATIONAL EVENT
ADVERTISING CAMPAIGN
NATIONAL TV AD BUYS:
30 :eccnc :pcl: cn LCGC. 8F/VC cnc 8EI
NATIONAL PRINT MEDIA BUYS:
/c 8uy: in lhe fc||cwin Nclicnc| FuL|icclicn:: C|ik Mcczine.
Swerv Magazine, Bleu Magazine, Urban Societies, Black Pride
Fe:cu(ce Guice. Dcm(cn: Men: I(cve| Guice
cf /c:: 1 F(imc(y Mc(kel: Nclicnwice Di:l(iLulicn
LOCAL PRINT MEDIA BUYS:
Marks List, Hotspots and Wire Magazine
WEB BLOG SUPPORTERS:
/c: cn Ihe Skc(picn Shcw. Lcve 8 Sccll. Fcc2.0. Dc Di(ly Fccic
Shcw. Gycnl Unp|uec. 3LWIV.ccm. D(cmc Dup(ee. Whcl:
lhe Iec. /DIV.ccm. Fulu(e Fc(wc(c IV.
NATIONAL PROMOTIONAL PARTNERS:
While Fc(ly {Mic). Winle( Fc(ly {Mic). lnfe(nc DF. Iemplec Ic
Icuch {Lc: Vec:). Fi(e l:|cnc 8|cck Cul. New Yc(k He(ilce cf
Pride, Miami Beach Pride, and more than 20 other promotional
partners nationwide.
PAID INTERNET WEB BANNERS:
cccm4cccm.ccm. mcnhunl.ccm. L|cckcychcl.ccm
RADIO:
Radio spots on local South Florida stations and Atlantas V103 FM
SIZZLEMIAMI.COM TRAFFIC (2009-10):
AVERAGE DAILY TRAFFIC
EXHIBIT L - 3
RECENT SIZZLE SPONSORS
AND PARTNERS
MIAMI HYATT REGENCY
EXHIBIT L - 4
Exc|u:ive Evenl Iil|e Spcn:c( {i.e. 8cnk cf /me(icc p(e:enl: Sizz|e 2011)
Exclusive selected team of individuals to promote your products and/or
services at events and host hotel
Exc|u:ive weL:ile hih|ihlin ycu( L(cnc p(ccucl cnc/c( :e(vice: {i.e.
www.:izz|emicmi.ccm/8C/.hlm|)
Mcjc( Di:p|cy cnc/c( Sel-up Iype cf cl Culccc( Lucu cnc cl hc:l hcle|
Fixec inle(nel Lcnne( cn cu( cffcic| www.:izz|emicmi.ccm weL:ile
Home & Event Page
Fixec inle(nel Lcnne( cn cu( cffcic| www.:izz|emicmi.ccm weL:ile
Event Page
Your signage and/or product displayed in the Beach/Luau Party VIP
Cabanas.
A dedicated e-blast sent by Us to our Sizzle Miami e-mail list
Ihe cppc(lunily lc ccncucl cn cclivily c( inle(cclive evenl lhcl :hcw-
cases Your Product
Prominent placement of sponsor logo at all events
Spcn:c(:hip |cc cn Sizz|e 2011 I-:hi(l:
Prominent placement of sponsor logo on all event entrance tickets
Hc:l Evenl ln Ycu( Ncme
Logo, products, and web link in Sizzle bi-weekly email blasts
Your promotional items included in bags distributed at luau and at host
hotel
Ccmp|imenlc(y Di:p|cy IcL|e @ Hc:l Hcle|
/c :ize in cffcic| evenl uice {15.000 ccpie:)
Prominent placement of sponsor logo/name on all promotional and
printed material
VlF pc::e: lc c|| cffcic| evenl:
Event Access With VIP Passes
Recognized as a sponsor along with Sizzle Miami, Inc in all press releases
and media announcements
Ycu( p(cmclicnc| ilem: inc|ucec cn ci:l(iLulicn lcL|e: cl |ucu /ND cl
host hotel
Website acknowledgment and hyperlink.
Media Sponsorships are values at 75% of actual ad placement cost to you.
F
F
E
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E
N
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G

S
F
C
N
S
C
F

$
3
0
0
0
0
F
L
/
I
l
N
U
M

S
F
C
N
S
C
F

$
2
0
0
0
0
G
C
L
D

S
F
C
N
S
C
F

$
1
0
0
0
0
S
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L
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E
F

S
F
C
N
S
C
F

$
5
0
0
0
8
F
C
N
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E

S
F
C
N
S
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$
2
5
0
0
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
lSL/ND
4
LOGO
10
ALL
X
X
X
X
X
X
X
X
X
X
X
X
X
2 I/8LES
2
LOGO
ALL
X
X
X
X
X
X
I/8LE
1 1/2
LOGO
4
ALL
X
X
X
I/8LE
1
N/ME
2
CLUBS
X
X
X
1
N/ME
1
CLUBS
X
X
X
2011 SPONSORSHIP LEVELS
EXHIBIT L - 5
TOP 10 GAY OUTDOOR EVENT
-F|cnelCul lnc. {Nc:ccc: LG8ID - New:). lhe
leading media and entertainment company ex-
clusively focused on the gay and lesbian market,
list Sizzle Miami among other notable national
events such as White Party and Winter Party, as
one of the nations top 10 gay outdoor events.
ATTENDEE ECONOMIC/
SOCIAL CHARACTERISTICS
0 c(e f(ecuenl l(cve|e(:
ve(y :ccic||y cclive {i.e. cinin cul. lhecle(. mcvie:.
c|uL:. elc)
cve(ce inccme |c(e( lhcn lhe nclicnc| cve(ce
enjcy: ci:pc:cL|e inccme
ecucclec. mc:l wilh cc||ee ce(ee:
wc(k in p(cfe::icnc| fe|c:
:ccic||y cclive cnc infuenlic|
evenl |cyc| {78 cllenc Sizz|e Micmi |c:l yec()
Luye(: cf hih-lickel ilem: {i.e. culcmcLi|e:. e|ec-
l(cnic:. (ec| e:lcle)
Leculy/ hec|lh cnc flne:: ccn:cicu:
fc:hicn ccn:cicu:/ l(enc:elle(:
8F/ND LCY/L
F|c(icc 20
Gec(ic 1
New Yc(k 14
lnle(nclicnc| 3
Iexc: 4
Mc(y|cnc 5
Cc|ifc(nic 5
New Je(:ey 4
Clhe( Slcle: {2) 11
l||inci: 3
Lcui:icnnc 2
Nc(lh Cc(c|inc 2
Fenn:y|vcnic 2
Wc:hinlcn D.C. 3
Michicn 2
GEOGRAPHIC ORIGIN OF
SlZZLE F/FIlClF/NIS
NOTE: CHART BASED ON 2010 PARTICIPATION
Vi(inic 3
EXHIBIT L - 6
EXHIBIT L - 7
PROMINENT SPONSOR
SIGNAGE AVAILABLE:
Sizzle Miami 2011 Luau
Sizzle Signature day event.
Miami Stage
Sizzle Beach Party on sunny Biscayne Bay.
Live entertainment, food, drinks, music.
Sizzle 2011 Headquarters
Located at the event host hotel visited
by attendees at least two times a day.
Sizzling Nightlife
Five nights of hot action at some South
Floridas sexiest nightclubs.
CONTACT:
Dwight Powell
CEO / Owner
305-38-12 {le|ephcne)
305-38-13 {fcx)
305-528-745 {ce||)
email: cpcwe||@:izz|emicmi.ccm
website: www.sizzlemiami.com
address: Platinum Planning Group
dba Sizzle Miami
3301 NE 1:l /ve. Suile 1103
Micmi. FL 33137-417
EXHIBIT L - 8
EXHIBIT J - 1
EXHIBIT J - 2
EXHIBIT J - 3
EXHIBIT J - 4
EXHIBIT J - 5
EXHIBIT J - 6
EXHIBIT J - 7
EXHIBIT J - 8
EXHIBIT J - 9
EXHIBIT J - 10
EXHIBIT J - 11
EXHIBIT J - 12
EXHIBIT J - 13
EXHIBIT J - 14
EXHIBIT J - 15
EXHIBIT J - 16
EXHIBIT J - 17
EXHIBIT J - 18
EXHIBIT J - 19
EXHIBIT J - 20
EXHIBIT J - 21
EXHIBIT J - 22
EXHIBIT J - 23
EXHIBIT J - 24
EXHIBIT J - 25
EXHIBIT J - 26
EXHIBIT J - 27
EXHIBIT J - 28
EXHIBIT J - 29
EXHIBIT J - 30
EXHIBIT J - 31
EXHIBIT J - 32
EXHIBIT J - 33
EXHIBIT J - 34
EXHIBIT J - 35
EXHIBIT J - 36
EXHIBIT J - 37
EXHIBIT J - 38
EXHIBIT J - 39
EXHIBIT J - 40

Flava Works vs. PLATINUM PLANNING GROUP, INC. D/b/a SIZZLE MIAMI and SIZZLE, LUIS MEDRANO and DWIGHT POWELL - Complaint and Exhibits

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Flava Works vs. PLATINUM PLANNING GROUP, INC. D/b/a SIZZLE MIAMI and SIZZLE, LUIS MEDRANO and DWIGHT POWELL - Complaint and Exhibits

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