Garcia

facts upon which the liability or defense is based”].)

2 that are collected by the Company” for each new client Garcia procured, and a $6,000 monthly advance on his commission. In October 2023, Garcia contacted SkyShowtime, a European streaming platform, about a documentary called Recipe for a Murder (the Documentary). Over the next few months Garcia worked closely with SkyShowtime to coordinate the project and “secured” cast members for the Documentary. The production negotiations for the Documentary were finalized in March 2024. The approved total budget was $1,668,863. Thailand Doc LLC, a wholly owned subsidiary of GMO, contracted to provide production services. According to its agreement with SkyShowtime, Thailand Doc would receive a “production fee” of $180,000 for its services. On March 21, 2024, Garcia spoke to Akim on the phone and asked about his commission. Garcia asserted that the project was “closing for $1.8 million” and therefore his commission would be “around $200,000.” Akim responded that Garcia’s commission would not be $200,000 because his commission would be based on GMO’s net revenue. Garcia asserted that his contract specified that his commission would be…