Electronically Filed

4/3/2020 1:26 PM
Steven D. Grierson
CLERK OF THE COURT

1 COMP
IAN CHRISTOPHERSON, ESQ.
2 Nevada Bar No.: 3701
3 LAW OFFICE OF IAN CHRISTOPHERSON
600 South Third Street CASE NO: A-20-813230-C
4 Las Vegas, Nevada 89101 Department 29
Telephone: (702) 372-9649
5 Email: Iclaw44@gmail.com
6 Attorney for Plaintiff, Joshua Ramos
DISTRICT COURT
7 CLARK COUNTY, NEVADA
8
9
JOSHUA RAMOS, aka ERNESTO CASE NO.:
10 JOSHUA RAMOS, an individual; DEPT. NO.:

11 Plaintiff,
12
vs. EXEMPT FROM ARBITRATION
13 [Arbitration Exempt Claimed:
DANA WHITE, an individual; UFC Amount in Controversy Exceeds
14 Holdings LLC, ZUFFA, LLC., doing $50,000.00
15 business as the ULTIMATE FIGHTING
CHAMPIONSHIP, a Nevada limited DEMAND FOR JURY TRIAL
16 liability company; DOES I through X,
inclusive; and ROE CORPORATIONS I
17 through V, inclusive;
18
Defendants.
19
20 COMPLAINT AND DEMAND FOR JURY TRIAL
21
COME NOW, Plaintiff, JOSHUA RAMOS, by and through Plaintiff’s attorney of record,
22
IAN CHRISTOPHERSON, ESQ., of the LAW OFFICE OF IAN CHRISTOPHERSON, and
23
hereby complains, alleges and avers as follows:
24
I.
25 PARTIES
26
1. At all times herein relevant, Plaintiff, JOSHUA RAMOS (hereinafter “RAMOS”),
27
28 was and is a resident of Clark County, Nevada.

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Case Number: A-20-813230-C

 1 2. Upon information and belief, at all times herein relevant, Defendant, DANA
2 WHITE (hereinafter “WHITE”), was and is a resident of Clark County, Nevada and the president,
3
manager and face of the ULTIMATE FIGHTING CHAMPIONSHIP and is the managing
4
member of its business entity UFC Holdings LLC.
5
6 3. Upon information and belief, at all times herein relevant, Defendant, ZUFFA,
7
L.L.C., is a Nevada limited liability company which was doing business as the ULTIMATE
8
FIGHTING CHAMPIONSHIP (hereinafter the “UFC”) which later sold the UFC to William
9
10 Morris Endeavor.

11 4. Defendants DOES I through X, and ROE CORPORATIONS I through X, are

12
unknown to Plaintiff who thereon sues said Defendants by such fictitious names. Plaintiff is
13
informed and believes and thereon alleges that each of the Defendants designated as DOES I
14
15 through X, and ROE CORPORATIONS I through X, are responsible in some manner for the

16 events and happenings herein alleged. Plaintiff will ask leave of Court to amend this Complaint to
17
insert the true names and capacities of DOES I through X, and ROE CORPORATIONS I through
18
X when the names have been ascertained by Plaintiff.
19
5. The acts, events and circumstances complained of and asserted in the instant
20
21 Complaint occurred in Clark County, Nevada.

22 II.
23 FACTS COMMON TO ALL COUNTS

24 6. That Plaintiff ‘s girlfriend (hereinafter Jane Doe) and with whom he resided and
25 had a child with was solicited or enticed to travel with Dana White in late October 2014 to Brazil
26
concurrent with a UFC event involving the Conor McGregor’s fight.
27
28

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 1 7. That White and Doe had no personal dating relationship prior to the trip, with their
2 contact limited to interactions at her place of employment, the Spearmint Rhino (hereinafter the
3
Rhino).
4
8. That White was accustomed to frequenting strip clubs including the Rhino and
5
6 interacting with the performers including Doe.

7 9. That Doe met White through her work as an entertainer at the Rhino strip club in
8
Las Vegas, Nevada and had paid Doe as much as $200,000 for “entertainment” prior to the trip.
9
10. That Doe separately traveled to Brazil on a first-class ticket and expedited passport
10
provided by the UFC to meet with White with the expectation she would be expected to engage in
11
12 sexual activity with White.

13 11. That also on the same trip, Whites in laws and co-owners of the UFC were
14
accompanied by other eye candy to whom they were not married.
15
12. That before taking the trip Doe was paid $5,000 or more.
16
17 13. On return Doe an additional $10,000 was delivered to the Spearmint Rhino for her

18 taking the trip with White, with only $8,000 reaching Doe.
19 14. That Doe recorded the sexual conduct in Brazil with White on her cellphone.
20
15. That Ramos downloaded a copy of the recording from Doe.
21
16. That Ramos, who was in a domestic relationship with Doe, became upset with Doe
22
23 and White and contacted White.

24 17. That after White denied any involvement with Doe, Ramos forwarded a video clip
25 of White on or about December 7, 2014 to establish that Ramos had grounds to confirm that white
26
had been involved with Doe.
27
28

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 1 18. That after that information/clip was sent to White, White, the UFC or their attorneys
2 contacted either the FBI or the US Attorney to allege White was being extorted.
3
19 That on December 11, 2014 White, UFC counsel Lawrence Epstein, Whites lawyer
4
Colby Williams and White met at the Campbell law office with AUSA Charles LaBella.
5
6 20. That White claimed he was a victim of extortion while at the same time stating that

7 he had arranged for Doe to travel to Brazil and given her a total of $15,000 or more for the trip.
8
21. There is no record of contact concurrent with that December 11th meeting of contact
9
with law enforcement from Nevada which would have had primary jurisdiction over extortion
10
committed in Nevada.
11
12 22. White and his in-laws had earlier purchased the UFC when it was having existential

13 issues with licensing and succeeded in getting licensed in Nevada under their ownership.
14
23. In 2015, after building the UFC into a business generating millions in revenue
15
White and his in-laws were considering or in the process of selling their interests in the UFC,
16
17 eventually selling it for nearly a four-billion-dollar profit in mid-2016.

18 24. That White was the face and front of the UFC.
19 25. That negative publicity could or would affect business and the sale if made public.
20
26. That White personally and/or his or UFC attorneys made contact with federal law
21
enforcement and prosecutors alleging that White was the target of extortion by Ramos.
22
23 27. That the purpose of that meeting to silence Ramos.

24 28. That White or his counsel expressed at the December 11th meeting that the
25 allegations if exposed could harm White and the UFC, a business they indicated was then valued
26
at over a billion dollars.
27
28

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 1 29. At that same meeting both White and his lawyers falsely represented to LaBella
2 and FBI Special Agent Mollica that Ramos was then a convicted felon on probation in Nevada, a
3
member of the Hells Angels and a pimp.
4
30. The same day the FBI (December 11, 2014) obtained records of Ramos’s criminal
5
6 record which rebutted that allegation.

7 31. That Whites attorneys made specific allegations referencing a specific criminal case
8
in Clark County Nevada for a Joshua Ramos (not Ernesto).
9
32. The statements by White, the UFC and their attorneys were false and reckless and
10
intend to influence the US Government to commence a process of criminal investigation and
11
12 prosecution.

13 33. That in seeking to have Ramos subject to criminal prosecution White made
14
statements that placed law enforcement on notice that he and/or the UFC had transported Doe out
15
of this country, engaged in sexual conduct and given Doe money, a prima facie Mann Act
16
17 violation.

18 34. That the information provided to LaBella on December 11th failed to provide or
19 establish a case for federal prosecution of Ramos.
20
35. That following said meeting on December 11th FBI Agent Mollica began to
21
monitor contacts and create a case upon which Ramos could be prosecuted in US District Court.
22
23 36. Though the White and his attorneys provided no evidence there had been a demand

24 for money or threat to publish the recording before December 11th, only texts indicating Ramos
25 was personally upset with White having had sex with Doe in Brazil, Agent Mollica began
26
quarterbacking the “investigation” to what arguably could be prosecuted as use of a cellphone to
27
aid an extortion plot.
28

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 1 37. That as of December 11th, 2014 the only criminal case the US Government had
2 probable cause to investigate was a potential self-reported violation of the Mann Act by White.
3
38. Instead the FBI sought to create a basis to prosecute the upset live in boyfriend of
4
Doe apparently without restriction and with the approval of the US Attorney’s office.
5
6 39. That White and his counsel sought thereby to silence Ramos and prevent

7 publication of the recording by having Ramos criminally prosecuted.

8
40. That despite indicating the recording having been made in Brazil and White’s
9
admission and later having an offer of proof from Doe that upon her return from White she was
10
paid $10,000 by White; no charges were brought against White.
11
12 41. Despite the fact that White had likely violated the Mann Act by taking Doe to Brazil

13 for compensated sex, White and his attorneys succeeded in White being labeled a victim and
14
having the FBI set up a sting/orchestrated payoff to Ramos for the tape.
15
42. That agent Mollica noted in his December 11,2014 report the position and
16
17 prominence of White.

18 43. That on January 7th and 8th, 2015 Agent Mollica created a sting, having Ramos meet
19 White in person so he could be videotaped.
20
44. At the first meeting White insisted that Ramos provide a figure for all copies of the
21
recording.
22
23 45. Ramos and White negotiated for a payment of $200,000 to be delivered the next

24 day.
25
46. That again on the 8th, of January 2015 Ramos met White and was given $200,000
26
in exchange for the recording.
27
28

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 1 47. That in his application for a search warrant filed before 2 pm January 8th 2015 Agent
2 Mollica detailed his active participation in creating and controlling the events and that he was
3
waiting for the payment he had essentially orchestrated that day to arrest Ramos.
4
48. That in the charging complaint and during the subsequent proceedings Whites
5
6 identity was not revealed by the US Attorney.

7 49. The US Attorney drafted and had counsel for Ramos execute a protective order
8
effective only during the prosecution which prevented disclosure of the name of White and also
9
provided for the ultimate destruction of the written discovery and video at the close of the case.
10
50. The stipulation for the protective order was dated September 30, 2015.
11
12 51. The following day disclosure of the tape was officially decriminalized in Nevada

13 on October 1, 2015 in NRS 200.770, which excluded sexual activity of a public figure as from
14
application of that statute.
15
52. After the court entered a protective order which was only effective during the
16
17 pendency of the criminal proceedings did White through his counsel contact counsel for Ramos to

18 offer to pay Ramos for a NDA after Ramos pled guilty.

19 53. Ramos was charged under the name Ernesto Joshua Ramos.
20
54. Nevada did not investigate the claimed extortion nor prosecute the extortion.
21
55. The US Attorney charged Ramos by indictment with using a phone in the aid of
22
23 extortion.

24 56. The US Attorney concealed White’s name.

25 57. Pursuant to the stipulation for a protective Order Whites identity was only
26
concealed through the close of the case after which Ramos was free to talk.
27
28

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 1 58. Ramos’s original private counsel was an acquaintance of White, Pete Christiansen.
2 59. Christiansen then represented Doe relative to this matter.
3
60. After Christiansen ceased to be his counsel, Ramos’s new counsel received a plea
4
agreement Ramos was considering in October 2015.
5
6 61. Unsolicited, White’s counsel called Ramos’s new counsel Gabriel Grasso and

7 advised that after Ramos entered his guilty plea White would pay Ramos for a nondisclosure
8
agreement to prevent any disclosure of White’s actions.
9
62. The protective order by its terms expired at the close of the prosecution, then set
10
for early 2016.
11
12 63. It was the US Attorney’s office, not Judge Navarro, who sought to and conceal

13 White’s identity and Judge Navarro later confirmed that White and Ramos could enter a NDA
14
separate of the criminal process through counsel.
15
64. After the sentencing closing the case the protective order would no longer bind
16
17 Ramos and White offered to pay Ramos for his silence as after sentencing Ramos he would be

18 freed from the protective order.

19 65. That Ramos accepted this offer and agreed to mediation to determine the amount
20
of compensation he and Doe were to receive.
21
66. That the parties White, the UFC, Doe and Ramos set a mediation for April 5, 2016.
22
23 67. The parties strangely agreed that Pete Christiansen who knew White personally and

24 had represented both Ramos and Doe related to the case was to act as mediator.
25 68. Ramos understood through his attorney Grasso that the amount could or would
26
approach or exceed one million dollars, whether that understanding was correct or not, Ramos
27
understood a reasonable figure would be paid to him.
28

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 1 69. That the mediation occurred on April 5, 2016 with the parties at different locations.
2 70. That by agreeing to the mediation White and the UFC acknowledged and agreed
3
Ramos was entitled to compensation for his silence.
4
71. That White and the UFC were at their offices for the mediation.
5
6 72. Previously White had agreed to pay $200,000 for the recording setting the baseline

7 for the mediation.

8
73. Ramos had reluctantly agreed to the guilty plea agreement prodded by the offer and
9
his counsel that he would be generously compensated for his silence after the plea, if he pled.
10
74. That the plea agreement and protective order both required forfeiture of the
11
12 recording.

13 75. By entering the plea agreement Ramos agreed the recording would be destroyed.
14
76. That nothing in the plea agreement or, the protective order or the terms of
15
supervised release as directed by the court constrained in any way Ramos from disclosing the
16
17 events at issue or Whites activities subsequent to completion of his sentence or earlier.

18 77. On April 5th, 2016 White and Ramos participated in a mediation to determine the
19 amount of compensation for the NDA agreement with Doe and Ramos.
20
78. White failed to offer Ramos a cent and only offered to double the amount already
21
paid to Doe to date, $15,000.
22
23 79. Despite his efforts to withdraw his plea the court denied the request, holding that

24 the offer to pay Ramos was independent from the criminal proceedings and affirming the effect of
25
the protective order not prohibiting disclosure by Ramos of the underlying events and action of
26
White.
27
28

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 1 80. Ramos was sentenced to a year and a day in prison with supervised release and has
2 now completed that sentence.
3
III.
4 FIRST CAUSE OF ACTION
(Breach of Contract)
5
6 81. Plaintiff, JOSHUA RAMOS, incorporates paragraphs 1 through 80 of the instant

7 complaint above as though set forth fully herein.

8
82. White and the UFC through counsel offered to pay Ramos for a nondisclosure
9
agreement subsequent to his entry of a guilty plea.
10
83. That the NDA was designed to protect the UFC and White.
11
12 84. Ramos agreed to what he understood was a precondition to the contract and his

13 mode of acceptance and pled guilty.

14
85. That the guilty plea’s ultimate effect would be to free Ramos from the terms of the
15
protective order after sentencing (the close of the case).
16
17 86. That after the plea the parties and Doe set a mediation to determine the amount of

18 compensation to be paid pursuant to the agreement.

19 87. That all parties understood the amount of compensation would be substantial.
20
88. That as expressed to the US Attorney on December 11th, 2014 disclosure could
21
affect the value of the UFC and White’s interest therein ( 9%) of a company they then valued at
22
23 over a billion dollars.

24 89. That as a result of the silence obtained from Ramos pursuant to their agreement
25 White and the UFC was sold in a sale which closed in June or July 2016 for an amount claimed to
26
be over four Billion dollars.
27
28

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 1 90. That the reasonable value of an NDA must reflect the value to White and the UFC
2 of concealing the negative information regarding White and Doe.
3
91. That on the date of the mediation White breached the agreement by not offering to
4
pay Ramos anything.
5
6 92. That Ramos has been damaged in excess of 15,000 thereby.

7 93. That the actions of White were fraudulent, oppressive and designed to encourage
8
Ramos to plead guilty so he could negotiate a substantial settlement which would prevent the
9
disclosure of his actions at trial for the personal benefit of White and his related businesses and
10
interests.
11
12 94. That punitive damages are appropriate.

13 SECOND CAUSE OF ACTION

(Contractual Breach of Implied Covenant of Good Faith and Fair Dealing)
14
15 95. Plaintiff, JOSHUA RAMOS, incorporates paragraphs 1 through 80 of the instant
16
complaint above as though set forth fully herein.
17
96. That White and the UFC owed the duty of good faith and fair dealing pursuant to
18
19 the covenant found in every contract.

20 97. That White and the UFC did not engage in fair dealing by their actions noted above.
21 98. That White and the UFC were motivated in part or in whole for this to conceal
22
White’s conduct during negotiations for the sale of the UFC.
23
99. That the failure to offer any payment to Ramos in April 2016 was in bad faith and
24
25 an abuse of his financial ability compared with Ramos.

26 100. That the precondition expressed to Ramos that the agreement was to be made after
27 entry of the plea was intended and had the affect of leading Ramos to believe he only would be
28
paid for a NDA if he pled guilty.

Page 11 of 14
 1 101. That subsequent to the April 2016 breach White confirmed the substantial value of
2 a NDA and offered to pay a combined total amount of $450,000 to Doe and Ramos.
3
102. That defendant’s action are outrageous and punitive damages are appropriate.
4
THIRD CAUSE OF ACTION
5
6 (Tortious Breach of the Implied Covenant of Good Faith and Fair Dealing)

7 103. For Plaintiff’s third cause of action Plaintiff hereby realleges the factual allegations set forth
8
in paragraphs 1-102.
9
104. Plaintiff and defendants entered into a contractual arrangement for a NDA with the amount
10
to be determined at a mediation set for April 5, 2016.
11
12 105. That the contractual arrangements began in October 2015 or early November 2015 with a

13 precondition that Ramos to have entered a guilty plea before the NDA negotiations would begin.
14
106. That Defendants breached their duty of good faith as set forth herein.
15
107. That Plaintiff suffered damages as a result of Defendants misconduct as a result thereof in
16
17 excess of $15,000dollars.

18 FOURTH CAUSE OF ACTION

(Unjust Enrichment)
19
103. For Plaintiff’s fourth cause of action Plaintiff hereby realleges the factual
20
21 allegations set forth in paragraphs 1 through 107.

22 104. That beginning at an unknow date and through the date of sale, White, the UFC and
23 the various owners of the UFC were privately entertaining offers to sell their ownership interest in
24
the UFC.
25
105. That White was an asset of the UFC as its manager and frontman.
26
27
28

Page 12 of 14
 1 106. That disclosure of not only the events in Brazil herein, but the subsequent events
2 resulting in and continuing through the date of sale and beyond would adversely affect the
3
marketability or sale price of the UFC.
4
107. That under the terms of the protective order as approved by judge Navarro
5
6 disclosure of White’s activities would be subject to disclosure as early as late February or early

7 March 2016 if Ramos pled guilty and was sentenced.

8
108. That White and the UFC recognized the short- and long-term benefit of reaching a
9
nondisclosure agreement with Ramos for the benefit of both White and the UFC.
10
109. This was recognized by White and the UFC when the protective order was entered
11
12 in October 2015.

13 110. That prior to the scheduled plea hearing in early November 2015 White’s counsel
14
contacted Gabriel Grasso advising that upon entry of a guilty plea by Ramos White wanted to
15
obtain a NDA from Ramos.
16
17 111. Though no figure was agreed upon it was mutually understood the compensation

18 for such agreement would be substantial.

19 112. As the sale was pending White and the UFC’s attorneys agreed to a mediation to
20
determine the amount of compensation on April 5, 2016.
21
113. At that meeting White and the UFC offered Ramos nothing.
22
23 114. That in early July 2016 the UFC was sold for a sum reported to be in excess of 4

24 Billion dollars.
25 115. That to this date White remains as manager and the face of the UFC, receiving a
26
reported annual salary of 20 million dollars.
27
28

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 1 116. That White and the UFC obtained the silence of Ramos by their actions and were
2 unjustly enriched both by the sale or its price not being affected by potential negative publicity,
3
lack of criminal investigation or charges and White’s continued employment with the UFC.
4
117. That White and the UFC have enjoyed and retained the benefit of Ramos’s silence
5
6 and were enriched thereby.

7 118. That the value of the benefits conferred on White and the UFC exceed $15,000.
8
119. That Whites actions are outrageous and punitive damages are appropriate.
9
IV.
10 DEMAND
11
Wherefore Plaintiff prays for the following relief:
12
1. Damages for breach of contract as determined by the court in excess of 15,000.
13
2. Damages in excess of 15,000 for breach of the covenant of good faith and fair dealing.
14
3. Damages for Defendants unjust enrichment based of the value of the UFC at the time of
15
sale enhanced by the non-disclosure of Whites conduct, an amount in excess of $15,000
16
dollars.
17
4. For punitive damages and attorney’s fees as allowed by law.
18
DATED this __3___ day of April, 2020.
19
20
/s/Ian Christopherson____________
21 IAN CHRISTOPHERSON, ESQ.
Nevada Bar No.: 3701
22
600 South Third Street
23 Las Vegas, Nevada 89101
Telephone: (702) 372-9649
24 Email: Iclaw44@gmail.com
25 Attorney for Plaintiff, Joshua Ramos

26
27
28

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