Below is the entire 73 page complaint alleging violations in the management contracts.

• First Cause of Action - for Breach of Contract
• Second Cause of Action - for Breach of Implied Covenant of Good Faith and Fair Dealing
• Third Cause of Action - for Breach of Fiduciary Duty
• Fourth Cause of Action - for Fraudulent Concealment
• Fifth Cause of Action - for Unfair and Deceptive Business Practice and Unfair Competition
• Sixth Cause of Action - for an Accounting

After the Woolley and Pacific Landmark cases, Butler predicted the legal principles of this line of cases would "forever change the landscape of hotel management agreements and the relationships between owners and operators." Many believe that Woodley Road and
other recent management disputes prove this out. If you would like to discuss these developments or have questions or points of view to share, you can contact Jim Butler at [email protected].