Cambron

I. BACKGROUND

24 a. Allegations in the Complaint 25 Defendant Scale Social is a California corporation. [Complaint (“Compl.”) ¶¶ 3–4.] 26 Defendant Gramajo is a resident of Arizona and the sole officer and director of Scale 27 Social. [Id. ¶ 6.] Plaintiff claims to be a model who works in the social media industry. 28 1 [Id. at 12.] Plaintiff entered into an agreement (the “Agreement”) with Defendants to have 2 Scale Social serve as Plaintiff’s talent management. [Id. ¶¶ 11, 18, 22.] Plaintiff alleges 3 that Defendants locked Plaintiff out of her social media accounts, failed to compensate 4 Plaintiff for her recruitment efforts, and wrongfully withheld Plaintiff’s profits generated 5 from her social media accounts. [Id. at ¶¶ 22–49.] 6 On December 31, 2024, Plaintiff filed a complaint asserting five causes of action 7 against Defendants. [See Compl.] Plaintiff first claims that the Agreement must be 8 declared null and void from inception because Defendants were not licensed under 9 California’s Talent Agencies Act (the “TAA”) and did not follow the TAA’s requirements. 10 [Id. ¶¶ 51–74.] Plaintiff next alleges that Defendants used false…