FILED: NEW YORK COUNTY CLERK 04/27/2015 12:03 AM
NYSCEF DOC. NO. 1

INDEX NO. 651391/2015
RECEIVED NYSCEF: 04/27/2015

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

ESPN, INC.,
Plaintiff,

Index No. ________

vs.
SUMMONS WITH NOTICE
VERIZON SERVICES CORP.,
Defendant.

TO THE ABOVE NAMED DEFENDANT:
PLEASE TAKE NOTICE THAT YOU ARE HEREBY SUMMONED
and required to serve upon Plaintiff’s attorney a notice of appearance or demand for a
complaint within twenty (20) days after service of this Summons with Notice, exclusive
of the day of service, or within thirty (30) days after service is complete if this Summons
with Notice is not personally delivered to you within the State of New York. In case of
your failure to appear or serve a demand for a complaint, judgment will be taken against
you on default for the relief demanded herein.
Plaintiff designates New York County as the place of trial. Venue is
proper because Defendant is registered to do business in New York and maintains offices
in this County, and many of the wrongful acts alleged herein occurred in this County.
NOTICE
This is an action for breach of contract and declaratory judgment arising
from Defendant’s breach of its obligations to Plaintiff under certain license agreements,

 supplements, and amendments entered into between Plaintiff and Defendant. Plaintiff
seeks specifically to enforce Defendant’s contractual obligations to Plaintiff, to enjoin
Defendant from unfairly depriving Plaintiff of the benefit of its bargain, and to require
Defendant to pay damages to Plaintiff in an amount consistent with (but not limited to)
relevant provisions in the parties’ agreements.
The relief Plaintiff seeks, in terms of specific performance, injunctive
relief, and damages, is equitable and legal.
Upon your failure to appear, judgment will be taken against you by default
for money damages in excess of $500,000, and interest thereon, together with reasonable
attorneys’ fees.

April 27, 2015
CRAVATH, SWAINE & MOORE LLP
by
/s/ Evan R. Chesler
Evan R. Chesler
Roger G. Brooks
J. Wesley Earnhardt
Members of the Firm
Worldwide Plaza
825 Eighth Avenue
New York, NY 10019
(212) 474-1000
Attorneys for Plaintiff ESPN, Inc.

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