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Tacopina vs Saputo.pdf


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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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JOSEPH TACOPINA,
Index No.
Plaintiff,
– against –

COMPLAINT

JOEY SAPUTO,

Plaintiff Demands Trial by
Jury

Defendant.
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Plaintiff, by his attorneys TACOPINA & SEIGEL complaining of the Defendant,
respectfully alleges as follows:
PRELIMINARY STATEMENT
1.

This Action arises from Mr. Tacopina obtaining an opportunity to purchase the

Bologna Football Club (“BFC”), an Italian Soccer Team, leading an investor group – including
Defendant Joey Saputo – that purchased BFC through a limited liability company, BFC1909
USA SPV, LLC (“BFC USA”) and then being betrayed by Mr. Saputo through Mr. Saputo’s
blatant breaches of an agreement between them.
2.

This agreement, more fully described below, was executed on or about December

1, 2014 after Mr. Saputo agreed to provide financing for BFC USA and was intended to: (a)
replace Mr. Tacopina as majority owner and provide Mr. Saputo with majority ownership of
BFC USA in exchange for said financing; (b) protect Mr. Tacopina’s ownership stake in BFC
USA from falling below approximately 30% by Mr. Saputo funding Mr. Tacopina’s obligations
to meet capital calls; and (c) set forth the terms of Mr. Tacopina’s position as President of BFC,
including Mr. Tacopina’s salary.