INDEX NO. 655382/2018
FILED: NEW YORK COUNTY CLERK 10/30/2018 03:15 PM NYSCEF DOC. NO. 2
RECEIVED NYSCEF: 10/30/2018
SUPR SU PREM EME E COUNTY -------
NEW NEW YO YORK RK
OF
OF NEW YORK
OF THE STATE
COUR CO URT T
==----
PR CONSULTING,
----------
------------------------X
:
INC.,
-against-
________--....--------.....-_
3.
:
Inc. ("PRC"),
aga gaiins nstt Luka Sabbat
PRC
PRC
place
is in the
business
Upon information
and
Wrobel
Markham
LLP,
as and and
Statte of t he he Sta
of New
for
existing
und un der
the th e la laws
in New York County.
l oc ocated
of providing
and belief,
as follows:
all lleg ege es
organized
of business
its attorneys,
by
("Sabbat")
is a corporation
its principal
2.
COMPLAINT
______ _..---------......... _..---------................-. .......-..X .X
PR Consulting,
Plaintiff
York, with
/ 201 2018 8
:
Defendant.
1.
No.
:
LUKA SABBAT,
Com ompl plai aint nt
:
Plaintiff,
its
Index In
Sabbat
public relations
services
individua viduall is an indi
to
residing
its clients.
in Kings County,
New York. Pursuant
4.
PRC êñgaged
"Agreement"),
connection
with
5.
four
of th the e
to an Influencer
Sabbat
Story posts
were
York Fashion Week
crea cr eate te
and an d
things,
Sabb Sa bbat at
(1) Instagram
agre ag reed ed
Feed Fe ed
undertaken
the
period
crea eate te to cr
Post and Post
to b e in in New York, rela relatted
(during
post po st certain co content
Marketing
Among other one on e
to
dated September
Campaign"
a "Spectacles
posts: s: (4) unique post
Agreement
thre th ree e
to fa fash shio ion n
of Septeñiber
1 of 4
6, 2018
forr fo
orig or igin inal al
15,
2018 201 8
(herei (he reinaf nafter ter
on
soci so cial al
medi me dia a
PRC's PRC' s
content
(3) Instagram
show sh ows s -
and an d
September
the
in
client, Snap, Inc.
for
a minimum
Two
Story posts.
part pa rtie ies s
during
12, 2018)
of
(2)
New
and an d
one
(1)
INDEX NO. 655382/2018
FILED: NEW YORK COUNTY CLERK 10/30/2018 03:15 PM NYSCEF DOC. NO. 2
RECEIVED NYSCEF: 10/30/2018
post
Story
Week
to be be
the th e
peri pe riod od
(during
September
prod pr odu uct
wearing
Post
Story
a provid provided ed
using
of
Septem Sep tember ber
tie ied d
to
the the
For
the
NYFW
for
Weeks,
Sabbat
during Fashion
Milan
was
to
or th the
include in
Marketing
Mila lan n
during
of
and
a swipe-up
photographed to be ph
agreed
period
Story Post
Instagram
Campaign'
'Sp Spec ecttac aclles
part pa rtie ies s
25, 2018
concluding
Sabbat
Additionally,
and an d
shows
September
or Pa Paris Fashion
Milan
hyperlink.
-
19, 2018
2, 2018).
for
to fashion
or Paris, re related
- October
24, 2018
one Instagram
CTA
in Milan
in w as as
in pu public
and an d
Paris Pari s
Fas ash hio ion n
Weeks.
review
and
Instagram
t ha hat
Sabbat
which wh
$45,000
24 h ou ours
Sabb bbat at to Sa
paid
the
ost Story p os
link,
photographed
and
1 Inst Instagram agram
in public
failed
the th
once
post
anal an alyt ytic ics s
was
(reac (re ach, h,
PRC ag agreed
foregoing,
upon up on
to be
to PRC
submitted
like li kes s
comm co mmen ents ts,,
and an d
for
for
views view s
to po post
Sabbat
1 additional
with or Paris, wi
in the
abbat to pay S ab
the
sum
of
$60,000
the Agreeme Agreement. nt.
signing
foregoing,
(1)
each
posting.
i n Milan story in
at least
that
with h PRC wit
of th the
for
Notwithstanding
one Instagram
swipe-up
was
provided
pr ov ovide
consider at ation
As
8.
would
within
Stories)
7.
of
further
The Agreement
6.
made only made
one on e
Instagr am am
Inst In stag agra ram m
and
f ai ailed
cities while
a fo foremêñtioned
Feed Post Post
and
in New York, wi w ith
story
a swipe-link,
a
to be
wearing
Spectacles
product.
9.
provide
for
his
Furthermore,
analytics
one
demanded
Based
that
Sabbat
to PRC for for
Instagram
10.
Sabbat
his hi s
feed
post
upon
t he th
return
firs fi rstt
were
did
submit
Inst In stag agra ram m
$ 45 45,000
past
PRC
that
the
Story,
provided
foregoing,
the
not
the
declared
PRC pai paid d
2 of 4
post
to PRC
as required required
prior
by
24-hour agreed 24
Sabbat
him. hi m.
to pasting
the
Agre Ag reem emêñ êñtt.
mark
fr om om
in breach o f the
and
f ai ailed
to
Ana nallyt ytic ics s
posting.
Agreement Ag
and
INDEX NO. 655382/2018
FILED: NEW YORK COUNTY CLERK 10/30/2018 03:15 PM NYSCEF DOC. NO. 2
RECEIVED NYSCEF: 10/30/2018
11.
paid
Sabbat
admitted
but
his default
nonetheless,
refused
to return
of the the
fund fu nds s
of paragraphs
1
any
by to him PRC.
CAUSE
FIRST
PRC
through
11 above
13.
PRC
PRC
and
attorney's
a result
is ent entitl itled ed
of the foregoing,
each
Sabbat
and
with
incidental
and
PRC
through
11 ab abov ove e
15.
ent ntit itlled
As
as iif f fully a result
to damages
incidental
repea eatts hereby rep
in
WHEREFORE,
with
int nter eres estt
plus
and an d
damages.
OF
ACTION AC
Enrichment)
each
and
of paragraphs
every allegation
1
set fort forth h herein.
of the the foregoing,
the amount the
and consequential
and realleges
of $45,000
amount am
consequential
(Unjust
of the Agreement
the terms
in the
AUSE SECOND C AU
14.
allegation
every
breached
damages
to compeñsatory
together
fees,
set forth herein.
as if fully
As
and realleges
repea eatts hereby rep
ACTION AC
of Contract)
(Breach
12.
OF
Sabbat
has been
of $45,000 plus int inter eres estt
unjustly
and an d
enriched
PRC
and
fees, together
atto at torn rney ey's 's
is
with
damages.
PR Consulting,
Plaintiff
Inc. demands
judgment
Luka against Luka
Sabb Sa bbat at
as
follows:
(a)
attorney's
On the the Fi Firs rstt Ca Cause fees, together
(b)
and attomey's
of Action,
with consequential
ause On the Second C au
fees, together
damages
and incidental
of Action,
with consequential
in the amount
damages
plu pl us interest
damages;
in the amount
and incidental
3 of 4
of $4 $45 5,0 ,000 00
damages;
of $45,00 $45,000 0
plus interest
and
INDEX NO. 655382/2018
FILED: NEW YORK COUNTY CLERK 10/30/2018 03:15 PM NYSCEF DOC. NO. 2
RECEIVED NYSCEF: 10/30/2018
The
(c)
other
Dated:
and further
New
relief
as
30,
disbur dis bursem sement ents s
the Court
New York
York,
October
and
costs
incurred
may deem
just
in
the within
action,
with
together
such
and proper.
WROBEL MARKHAM
LLP
2018
By:
, 5'teve
. Fox,
Attorneys
for Plaintiff
360 Lexington 11th
sq.
Avenue,
FlOOr
New
York,
(212)
421-8100
NY
10017
Suite
1502
