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Virgin Islands Summer Splash: Paid4Ent. vs. Young Jeezy et al Civil Case No. 3:11-cv-70 Filed: 06/24/11


I came across this while browsing Facebook. The saga continues and this time Paid 4 Entertainment has raised the ante with a civil suit. We’ll keep you posted as the case unfolds…

IN THE DISTRICT COURT OF THE VIRGIN ISLANDS

DIVISION OF ST. THOMAS AND ST. JOHN

PAID 4 ENTERTAINMENT, LLC.,

JERMAINE SAUNDERS and JASON SAUNDERS,

Plaintiffs,

v.

JAY JENKINS, a/k/a YOUNG JEEZY, YOUNG JEEZY TOURING, LLC, MELINDA SMITH, SMITH BY SMITH ENTERTAINMENT, INC.,

Defendants.

CIVIL NO. 3:11-cv-70

ACTION FOR DAMAGES

JURY TRIAL DEMANDED

COMPLAINT

Plaintiffs, by and through undersigned counsel, allege a complaint as follows:

1. This Court has jurisdiction pursuant to 28 U.S.C. §1332 since the amount in controversy exceeds the sum of Seventy-Five Thousand Dollars ($75,000.00), exclusive of interest and costs and is between citizens of different states.

2. Plaintiffs demand trial by jury of the within action.

3. Plaintiff, Paid 4 Entertainment, LLC, is a Limited Liability Company created and existing under the laws of the U.S. Virgin Islands.

4. Plaintiff, Jermaine Saunders, is a resident and citizen of the Virgin Islands, residing in St. Thomas, U.S. Virgin Islands.

5. Plaintiff, Jason Saunders, is a resident and citizen of Temple, Texas. Case: 3:11-cv-00070-CVG -RM Document #: 1 Filed: 06/24/11 Page 1 of 9

Complaint Page 2 of 9

Paid 4 Entertainment, LLC, et al. v Jay Jenkins aka Ýoung Jeezy, et al.

______________________________________________________________

6. Defendant, Jay Jenkins, also known as Young Jeezy, is on information and belief, a resident and citizen of Atlanta, Georgia.

7. Defendant, Young Jeezy Touring, LLC, is according to its name, a Limited Liability Company that on information and belief was formed and is existing under the laws of the state of Georgia.

8. Defendant, Melinda Smith, is a resident and citizen of the state of New York, residing at 96 Sagebrush Lane, Islandia, New York.

9. Defendant, Smith by Smith Entertainment, Inc., is purportedly a corporation, organized under the laws of some unknown state and which uses the address of 96 Sagebrush Lane, Islandia, New York.

COUNT I

BREACH OF CONTRACT

10. Since approximately November or December 2010, Plaintiffs began planning for “VI Summer Splash 2011”, a summer concert in which Jay Jenkins, also known as “Young Jeezy” would be sought as the headlining attraction.

11. On or before March 1, 2011, Plaintiffs contacted representatives of Caribbean Entertainment.Com, Inc., a booking agent, for the purpose of securing the performance of Defendant, Jay Jenkins, a/k/a Young Jeezy, to headline the VI Summer Splash event. Case: 3:11-cv-00070-CVG -RM Document #: 1 Filed: 06/24/11 Page 2 of 9

Complaint Page 3 of 9

Paid 4 Entertainment, LLC, et al. v Jay Jenkins aka Ýoung Jeezy, et al.

______________________________________________________________

12. On March 2, 2011, Defendant, Young Jeezy Touring LLC and Jay Jenkins entered a contract with its/his agent Caribbean Entertainment.Com, Inc., to perform as the headline act in Summer Splash 2011; a performance that was booked for June 18, 2011 at the Lionel Roberts Stadium, on St. Thomas, U.S. Virgin Islands.

13. The Plaintiffs, as promoters and the persons ultimately responsible for the planning and the payment of all persons who were to perform at V.I. Summer Splash 2011, were the intended third-party beneficiaries of this contract.

14. On March 4, 2011, Caribbean Entertainment.Com, Inc., as agent to Jay Jenkins, and Young Jeezy Touring, LLC, (sometimes herein after referred to as the “Jeezy”) entered into a contract with Paid 4 Entertainment and promised the performance of Young Jeezy at Summer Splash 2011 on June 18, 2011.

15. The terms of the contracts of March 2, 2011 and March 4, 2011 were identical in every particular concerning the performances required by the artist, (Young Jeezy), and those required by the Plaintiffs, with the only distinction being that Plaintiffs were required to pay Two Thousand Five Hundred Dollars ($2,500.00) as the booking agent fee.

16. That pursuant to the terms of the contracts, Plaintiffs paid an initial deposit of Twenty-Seven Thousand Five Hundred Dollars ($27,500.00) [representing the required $25,000.00 deposit to the artist and the $2,500.00 agent fee], toward the Fifty-Two Thousand, Five Hundred Dollars ($52,500.00) agreed upon contract price for the performance. Case: 3:11-cv-00070-CVG -RM Document #: 1 Filed: 06/24/11 Page 3 of 9

Complaint Page 4 of 9

Paid 4 Entertainment, LLC, et al. v Jay Jenkins aka Ýoung Jeezy, et al.

______________________________________________________________

17. That in consideration of the initial deposit paid by Plaintiffs and received by the Defendants, and the agreement of Plaintiffs to provide additional compensation at the time and in the amount agreed, Defendants agreed that Jay Jenkins (Young Jeezy) would perform at V.I. Summer Splash 2011 as the headline performer on June 18, 2011 at the Lionel Roberts Stadium on St. Thomas, U.S.Virgin Islands.

18. That Plaintiffs performed completely and fully in accordance with the contract terms; secured sponsors, commenced a regional and national advertising campaign and otherwise did expend large sums of money in anticipation of Defendant’s promised performance at the V.I. Summer Splash 2011 event.

19. That pursuant to the contract, Defendant prepared radio drops and approved advertising containing the likeness of “Young Jeezy” announcing and promoting the performance of the Defendant at V.I. Summer Splash 2011 on the June 18, 2011 agreed date.

20. On or about June 6, 2011, just twelve (12) days before the scheduled performance of Young Jeezy, and after the expenditure of large sums to advertise that performance, Defendant’s agent, Caribbean Entertainment.Com, LLC notified Plaintiffs that “Young Jeezy” might have a conflict and was considering not appearing on June 18 at V.I. Summer Splash 2011 as previously agreed.

21. That upon receiving this notice, Plaintiffs immediately wrote to Defendant’s agent, stating the hardship that such a non-appearance decision would cause to Case: 3:11-cv-00070-CVG -RM Document #: 1 Filed: 06/24/11 Page 4 of 9

Complaint Page 5 of 9

Paid 4 Entertainment, LLC, et al. v Jay Jenkins aka Ýoung Jeezy, et al.

______________________________________________________________

Plaintiffs and their sponsors, and to impress upon the Defendants, the loss and damage that would result.

22. That Plaintiffs remained in contact with Defendant’s agents over the following days in an attempt to dissuade Defendants from the anticipated breach and to attempt to avoid the damages that would result from Defendant’s failure to perform.

23. That in an attempt to salvage the V.I. Summer Splash 2011 event and to mitigate the losses that would be occasioned by Defendant’s (Young Jeezy’s) failure to perform, Plaintiffs requested that Defendant agree to perform on June 19, 2011.

24. That Defendants, (Jeezy), by and through its agent, Smith by Smith Entertainment, Inc., and Melinda Smith, drafted a contract whereby Defendant, Young Jeezy agreed to appear and perform at V.I. Summer Splash 2011 on the alternate date of June 19, 2011.

25. That Plaintiffs executed a new contract on June 16, 2011 and transmitted the executed copy of the contract to Defendants pursuant to their instructions.

26. That pursuant to the terms of this new contract, Plaintiffs were required to make an immediate additional deposit of Five Thousand Dollars ($5,000.00) and to pay for a private jet to transport Defendant, Jay Jenkins (Jeezy) to and from the U.S. Virgin Islands.

27. That on June 17, 2011 the Plaintiffs caused the required deposit to be wire transferred pursuant to Defendants’ instructions and scheduled and paid for a private plane at a cost of approximately Twenty-Five Thousand Dollars ($25,000.00) to Case: 3:11-cv-00070-CVG -RM Document #: 1 Filed: 06/24/11 Page 5 of 9

Complaint Page 6 of 9

Paid 4 Entertainment, LLC, et al. v Jay Jenkins aka Ýoung Jeezy, et al.

______________________________________________________________

transport the performer and his designees to the Virgin Islands for the concert and to return them to the Atlanta area.

28. That despite Plaintiffs’ efforts to mitigate the effects of Defendant’s failure to perform on June 18, 2011 as agreed and despite Plaintiffs execution of a new contract changing the date of performance to June 19, 2011 and making the additional deposit and paying for a private jet, Defendant, Young Jeezy, failed to board the jet at the appointed time, failed to travel to St. Thomas on the prepaid jet, and failed to perform at VI Summer Splash 2011 on June 19, 2011 as agreed.

29. That Plaintiffs were notified by the airplane charter company on June 19, 2011 of Defendant’s failures and at approximately 4:30 p.m. on this same date heard from Defendant’s Representative that Defendant Young Jeezy would not appear at V.I. Summer Splash 2011 as agreed.

30. That as a direct and proximate result of Defendant’s failure to perform, the V.I. Summer Splash events of June 19, 2011 were cancelled, V. I. Summer Splash 2011 was never completed, and Plaintiff’s incurred incidental and consequential damages.

COUNT II

FRAUD AND FRAUDULENT MISREPRESENTATION

31. All allegations of Count I are incorporated herein by reference as if set forth at length. Case: 3:11-cv-00070-CVG -RM Document #: 1 Filed: 06/24/11 Page 6 of 9

Complaint Page 7 of 9

Paid 4 Entertainment, LLC, et al. v Jay Jenkins aka Ýoung Jeezy, et al.

______________________________________________________________

32. That the contracts entered, promises made, and representation made and advanced by Defendants Jay Jenkins, Young Jeezy Touring, LLC., Melinda Smith and Smith by Smith Entertainment, Inc., were untrue, intentionally made and made with the intent to defraud the Plaintiffs of money.

33. That Defendant Jenkins acted by himself and through agents knowing that he had no intention of performing, and with the purpose of enriching himself to the loss and damage of the Plaintiffs.

34. That as a direct and proximate result of Defendants’ fraud and fraudulent misrepresentations, Defendants are liable to the Plaintiffs for such compensatory and punitive damages as proven at trial.

COUNT III

INTENTIONAL OR NEGLIGENT MISREPRESENTATION

35. All allegations of Counts I and II are incorporated herein by reference as if set forth at length.

36. That Defendant Jay Jenkins, and other defendants acting with or on his behalf made representations promising to appear and perform at V.I. Summer Splash 2011 when Defendant knew that he was scheduled to appear and perform in the Atlanta area on June 18, and 19, 2011. Case: 3:11-cv-00070-CVG -RM Document #: 1 Filed: 06/24/11 Page 7 of 9

Complaint Page 8 of 9

Paid 4 Entertainment, LLC, et al. v Jay Jenkins aka Ýoung Jeezy, et al.

______________________________________________________________

37. That Plaintiffs reasonably relied on the intentional or negligent representations of the Defendants, all to their loss and damage.

38. As a direct and proximate result of the intentional or negligent misrepresentations of the Defendants, the Plaintiffs have suffered loss and damage.

COUNT IV

CIVIL CONSPIRACY AND PRIMA FACIE TORT

39. All allegation of Counts I, II and III are incorporated herein by reference as if set forth at length.

40. That Defendants Jenkins and Smith conspired and acted in concert with each other and through entities of questionable legal validity to fraudulently steal and swindle money from the Plaintiffs, all to Plaintiffs’ damage.

41. That the actions of Jenkins and Smith were willful, intentional and purposefully done with the intent to harm and damage the Plaintiffs.

42. That as a direct and proximate result of the civil conspiracy and prima facie tort of the Defendants, the Plaintiffs have suffered pecuniary damage and loss, damages to their business and professional reputations and are entitled to the award of such compensatory and punitive damages as may be proven at trial. Case: 3:11-cv-00070-CVG -RM Document #: 1 Filed: 06/24/11 Page 8 of 9

Complaint Page 9 of 9

Paid 4 Entertainment, LLC, et al. v Jay Jenkins aka Ýoung Jeezy, et al.

______________________________________________________________

WHEREFORE, Plaintiffs pray this Honorable Court grant judgment against Defendants, jointly and severally:

(a) for such amount of compensatory and punitive damages as proven at trial;

(b) awarding costs and attorneys fees of the action;

Together with such other and further relief as to the Court may seem just, equitable and proper.

DATED: June 24, 2011 /s/ Robert L. King, Esquire_______________

ROBERT L. KING, ESQUIRE

LAW OFFICES OF ROBERT L. KING, ESQ.

1212 Bjerge Gade, P.O. Box 9768

St. Thomas, Virgin Islands, 00802

VI Bar no. 188

340-776-1014 Fax. 340-774-5299

rlking@attyking.com

Case: 3:11-cv-00070-CVG -RM Document #: 1 Filed: 06/24/11 Page 9 of 9

Source: Paid 4 Entertainment Massive

Sincere: 1 on 1


I recently had the opportunity to interview one of my favorite V.I. artists Sincere in a studio session at I-Grade Studio in Downtown Christiansted. Here’s my 1 on 1 with this talented entertainer:

Joz: Where did the name Sincere originate?

Sincere: Back in the days when we (Deh Fam) first started recording, writing, and playing around I was doing a lot of girl songs (romantic songs) and in a couple songs I used the line “I’m so sincere” and people were like you’re always with this sincere sh*t and everybody just started with Sincere, Sincere, Sincere and it kind of stuck… you know what I mean.

Joz: When did you make the decision to pursue a musical career?

Sincere: Well I’ve always been around music from a young age. My uncle used to produce for Desiree, Midnite, Adonai home grown albums…so,  we used to be around Glamorous Studios and then I was always messing with beats but then I started taking it more seriously around 11th grade.

Joz: The rumor is that you cater to the ladies…Is there any truth to that?

Sincere: Ummm, to a certain extent you know what I mean?… I feel like I’m real comfortable talking to females. So, I listen to a lot of females and what they’re going through.  I tend to write music towards them because of what they’ve told me.  I’ve gotten a better aspect and understanding of different feelings from females…but at the same time I like to talk about life situations. You won’t really hear me talking about too much club stuff or street sh*t.  I’ll do club and street stuff once in a while but not too much. You know what I mean?

Joz: Yeah I do…In the rap/ hip hop arena what branch do you consider your work to be?

Sincere:  Well, I consider it hip hop overall. I tend to not stick in one lane. I prefer to cover all bases that way I can attract a larger fan base; as opposed to if I stuck to club music for instance.  I feel that if I chose to stay in one lane I’d miss out on the opportunity to make deep and introspective music that makes you think a lot…You know what I mean?

Joz: Who are your major influences?

Sincere: Umm, my uncle Ira Hewitt, Jr., I also like Bob Marley, Jay-Z, Nas, Tupac, Biggie those artists have influenced me…they stick to the real hip hop and essence of the music.

Joz: When you perform which of your songs do you include in your set?

As far as the group goes the song by SK called “Gun Talk” is a favorite. I personally, like to perform the “How Low Remix” the girls love that…“Good Girl” and the “Hard” Remix are also songs that I include in my set.

Joz: Who do you currently listen to that’s mainstream?

Sincere:  Right now, I listen to J. Cole, Joe Budden, Jay-Z, and Drake here and there. I like a lot of the upcoming artists like Wale and the artists that speak things that make you think, with stories that make you wonder where they’ve been all the while (laughs)… and I wonder how they came up with it. I don’t care too much for the dance music and the Soulja Boys. It doesn’t interest me too much.

Joz: How has your music evolved since you first began?

Sincere: When I first began it wasn’t as precise… Over time I have a developed a better sound that’s more consistent. Before I would do a verse and think it was crazy and then I’ll do another  verse and I’d listen back and I would be like damn I fell off on that verse…but now I feel it’s more consistent and the flow is on a far higher level than it was before.

Joz: You’re a part of Deh Fam what do you bring to the group that sets you apart?

Sincere: I bring a deeper aspect. In the group like you’ll have the street lyricists which are Shiest and SK. I’ll have more stories and groupie lines and delivery that are on another level. I’ll just have more laidback stuff with a lot of focus on the ladies and life stories that people can relate to…you know.

Joz: What is the biggest challenge of being a member of a group?

Sincere: In a group you have different personalities; so you kind of have to deal with certain things.  If it was just me alone I would just have to deal with me…but in the group someone may have a bad day today but we’ve been around each other from a young age so we basically help each other out. For instance, if I know Snipes doesn’t like a certain thing I can kind of interject and cut it off ‘because I know Snipes. So I’ll be like Snipes isn’t into this or that…we tend to have fewer issues but if we do have issues we suppress it real quick ‘cause we all grew up together.

Joz: What’s the ultimate direction for Deh Fam?

Sincere: To be as successful as possible…To make as many connects as possible and to leave an impact on the music industry and entertainment world.

Joz: As a solo artist how have you nurtured your career?

Sincere: I have basically been writing a lot…My mission right now is to really record as much as possible and by doing so I will remix as many songs as possible… that way every time I write I get better. The more I record mixtape tracks it prepares me for my original songs and it’ll make me much better lyrically.

Joz: How do you acquire musical inspiration?

Sincere: Ummm, to me musical inspiration comes from all over. I’ll be driving down the road and I’ll see a lady struggling with her bags and a child…This will lead me to consider what she goes through on a daily basis. Then, I’ll start writing a song towards that or I might go to the club and see four girls getting drunk and one dude goes home with 4 of them… and I’ll  think of a story like, I wonder what could’ve possibly happened and I’ll create a story for that. Anything can be an inspiration basically.

Joz: Let’s say you’re in the middle of writing a song…Do you need to hear a beat 1st or do you write and have the track based around your flow?

Sincere: I can do it both ways but for the most part I prefer to have the track, so, that way I can craft the lyrics and the flow specifically to that beat. We work with a bunch of different producers that are extremely talented; so, I might be home one day without any beats and I’ll get a concept in my head… start writing, bring it to one of our producers and then they’ll sit down build a track around it.  So, yeah it can go both ways but I prefer to write to a beat.

Joz: Do you have any upcoming projects or shows in the future?

Sincere: Right now we‘re working on a couple of projects nothing’s set in stone… MH (Masai Harris) & I are working on the”707, I’m working with Slik on my installment of We Run Da VI Series, and I’m working on my solo mixtape ‘Welcome to Sin City’. So I’ve basically been recording a lot of songs. Slik is a beast putting together mixtapes; so, I’m going to put together 15-16 tracks and let Slik do Slik. Prya and I are gearing up for the VI Summer Splash with Jeezy set for June 17-18. 

Joz: Is there anyone you’d like to acknowledge for providing support?

Sincere: My whole team basically…we have a big team and we help each other in more than one way. Shoutouts to all the artists that have ever looked out for us…Benny D, Verse, & Rock City…All the promoters that have given us a chance to perform at big shows and  travel for free. Basically everyone that has supported Deh Fam, Krunkmaster DJ Slik, Jahlion Sound Movements, and I as a solo artist. All of the people that have been supporting us by buying mixtapes, commenting  on our music, performances, and requesting us on the radio…All of the local DJs and anyone that supports us  in general big respect to them.

Joz: How can fans connect with you?

Sincere: You can check me out online at:

www.facebook.com/dehfamsincere

www.reverbnation.com/sinceredehfam

www.youtube.com/dehfamsincere

www.twitter.com/dehfamsincere

Joz: Any last words…?

Sincere:  Just keep supporting VI music…we come from a small place, but if you see someone trying to do something positive and you can reach out and giving a helping hand… Why not? Support all local artists, VI artists…the artists that are actually working hard. Not everyone just picks up the mic, starts rapping, and tags everyone in their videos. On the other hand if you’re really serious and this is your craft I support everybody. Yeah, keep the music going and keep it positive. 

Experience Sincere on the deeper side in one of his best features  to date with fellow V.I. artist Ryan J. below:

@JozBiz