UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

SAMUEL HERNANDEZ, RICHARD 

MONTOURE, and MARCY BROOKS on 

behalf of themselves and all others similarly 

situated,

Plaintiffs, 

v. 

EVENT ENTERTAINMENT GROUP, INC., 

Defendant.

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Case No.: 20-cv-22495

CONSOLIDATED CLASS ACTION 

COMPLAINT

 DEMAND FOR JURY TRIAL

Plaintiffs Samuel Hernandez, Richard Montoure, and Marcy Brooks individually and on 

behalf of all others similarly situated, by and through counsel, bring this action against Defendant

Event Entertainment Group, Inc. (“EEG”). Plaintiffs’ allegations herein are based upon personal 

knowledge and belief as to their own acts, upon the investigation of their counsel, and upon 

information and belief as to all other matters. 

INTRODUCTION

1. Plaintiffs bring this action on behalf of themselves and a class of similarly situated

purchasers of tickets to the 2020 Ultra Music Festival (“Ultra”), an annual festival held in Miami, 

Florida. 

2. This year, the Ultra Music Festival was scheduled to take place from March 20 to

March 22, 2020 in Miami, Florida. Due to the spread of COVID-19, however, the City of Miami

and EEG agreed to cancel the festival, while publicly framing the decision as one to “postpone” 

the 2020 festival until sometime in 2021. 

3. After learning of the cancellation, Plaintiffs and other similarly situated purchasers

contacted EEG for refunds. EEG has uniformly denied these requests and offered only to honor 

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tickets during either the 2021 or 2022 Ultra Music Festival, neither of which has been scheduled

nor, given the current state of the pandemic in Florida, appears likely to occur. 

4. Adding insult to injury, in an effort to coerce Plaintiffs and Class members to forfeit 

the cash value of the tickets they purchased for an event that will not take place, EEG also told

customers they had only 30 days to choose which festival they would like to have their 2020 tickets 

transferred to or they would lose the right to do so. EEG repeatedly has extended the deadline, 

however, because Plaintiffs and other Class members are reluctant to agree to defer their tickets in 

lieu of receiving the refund to which they are entitled.

5. Accordingly, Plaintiffs bring this action for conversion and unjust enrichment in 

order to recover amounts paid for tickets to the 2020 Ultra Music Festival.

PARTIES

Plaintiff Samuel Hernandez

6. Plaintiff Samuel Hernandez is a resident of Miami, Florida.

7. On or about September 24, 2019, Plaintiff Hernandez purchased six tickets to Ultra 

for approximately $3,000.

8. On or about March 9, 2020, Plaintiff Hernandez received an email from EEG with 

the subject “Ultra Miami 2020 Rescheduled.” In the email, EEG informed Plaintiff that the 2020 

festival was cancelled, that he could “transfer” his tickets to either the 2021 or 2022 iteration of 

the festival by filling out and returning an attached form, and that the offer to defer his tickets to a 

subsequent year would remain open for only thirty (30) days.

9. When Plaintiff Hernandez learned that Ultra had been cancelled, he attempted to 

contact EEG to obtain a refund for his tickets.

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10. On or about March 10, 2020, Plaintiff Hernandez first attempted to locate a 

telephone number at which he could call EEG to obtain a refund, but was unable to locate one.

Plaintiff Hernandez then emailed EEG to request a refund for four of his Ultra tickets

11. On or about March 13, 2020, EEG responded to Plaintiff Hernandez’s email. EEG

ignored Plaintiff Hernandez’s refund request and directed him to “fill out the form found in the 

email [he] received earlier this week to confirm the package of benefits that are being offered.”

EEG also reminded Plaintiff Hernandez that its deferral offer would only remain open until April 

8, 2020, and confirmed that it considered all festival tickets non-refundable. 

12. On or about March 17, 2020, Plaintiff Hernandez sent an email to EEG indicating 

that that he “WILL NOT accept for the 4 tickets that should have never been passed due to incorrect 

billing address. I ask to find compromise in refunding my 4 and ill accept the 2 other.”

13. Because Plaintiff Hernandez did not want to lose the entire value of his Ultra tickets 

and because EEG did not provide him any other option, he claimed his benefits for two of his 

tickets on or about May 20, 2020.

14. As of the filing of this complaint, Plaintiff Hernandez has not received a refund for 

any of his Ultra tickets.

Plaintiff Richard Montoure

15. Plaintiff Richard Montoure is a resident of Grayland, Washington.

16. On or about November 23, 2019, Plaintiff Montoure purchased two General 

Admission 3-day Tier 3 passes to the Ultra Music Festival, paying approximately $1,032.30 

inclusive of taxes and fees.

17. On or about March 9, 2020, Plaintiff Montoure received an email from EEG with 

the subject “Ultra Miami 2020 Rescheduled.” In the email, EEG informed Plaintiff that the 2020 

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festival was cancelled, that he could “transfer” his tickets to either the 2021 or 2022 iteration of 

the festival by filling out and returning an attached form, and that the offer to defer his tickets to a 

subsequent year would remain open for only thirty (30) days.

18. Plaintiff Montoure does not plan to attend the Ultra festival in 2021 or 2022, so he 

attempted to contact EEG in order to secure a full refund.

19. Plaintiff Montoure first attempted to locate a telephone number at which he could 

call EEG to obtain a refund, but was unable to locate one. Accordingly, on or about March 18, 

2020, Plaintiff Montoure sent an email to EEG requesting a refund for the purchase price of his 

tickets.

20. EEG did not respond to Plaintiff Montoure’s refund request.

21. On or about March 27, 2020, Plaintiff Montoure received an email from EEG

informing him of the purported April 9, 2020 deadline to claim his “benefits” for future festivals. 

22. Because Plaintiff Montoure did not want to lose the entire value of his Ultra tickets 

and because EEG did not provide him any other option, he “claimed [his] benefits” on or about 

April 7, 2020.

23. Despite claiming his benefits on April 7, 2020, on or about April 9, 2020, 

Plaintiff Montoure received an email from EEG indicating that the deadline to claim his benefits 

was extended from April 9, 2020 to May 7, 2020.

24. Despite claiming his benefits on April 7, 2020, on or about May 4, 2020, 

Plaintiff Montoure received an email from EEG indicating that the FINAL deadline to claim his 

benefits was extended from April 9, 2020 to May 7, 2020.

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25. Despite claiming his benefits on April 7, 2020, on or about May 12, 2020, 

Plaintiff Montoure received an email from EEG indicating that the deadline to claim his benefits 

was extended to July 1, 2020.

26. Plaintiff Montoure still has not received a refund for his Ultra tickets.

Plaintiff Marcy Brooks

27. Plaintiff Marcy Brooks is a resident of Los Angeles, California. 

28. On or about January 14, 2020, Plaintiff Brooks purchased one ticket to Ultra for 

approximately $525.60.

29. On or about March 9, 2020, Plaintiff Brooks received an email from EEG with the 

subject “Ultra Miami 2020 Rescheduled.” In the email, EEG informed Plaintiff Brooks that the 

2020 festival was cancelled, that she could “transfer” her ticket to either the 2021 or 2022 iteration 

of the festival by filling out and returning an attached form, and that the offer to defer her ticket to 

a subsequent year would remain open for only thirty (30) days.

30. Plaintiff Brooks does not plan to attend the Ultra festival in 2021 or 2022, so she 

attempted to contact EEG in order to secure a full refund. 

31. On or about March 12, 2020, Plaintiff Brooks sent an email to EEG requesting a 

refund for the purchase price of her ticket.

32. On or about March 12, 2020, Plaintiff Brooks received an email response from EEG

stating “We understand your frustration with the news of the Ultra Music Festival having to 

reschedule their festival .... Unfortunately ... tickets are non-refundable.” 

33. Plaintiff Brooks still has not received a refund for her Ultra ticket.

Defendant

34. EEG is a Florida corporation with its principal place of business in Miami, Florida.

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35. EEG schedules, oversees, organizes, and manages the annual Ultra Music Festival

in Miami-Dade County. 

 JURISDICTION AND VENUE

36. This Court has subject matter jurisdiction pursuant to the Class Action Fairness 

Act, 28 U.S.C. § 1332(d). The aggregated claims of the individual class members exceed the sum 

or value of $5,000,000, exclusive of interest and costs; there are more than 100 putative class 

members defined below; and there are numerous members of the proposed class who are citizens 

of a state different from EEG.

37. This Court has personal jurisdiction over EEG because it is formed under the laws 

of the State of Florida, its corporate headquarters are located in this District, and it conducts 

substantial business in the District, and because a substantial part of the acts and omissions 

complained of occurred in the District.

38. Venue as to EEG is proper in this judicial district under 28 U.S.C § 1391 because 

a substantial part of the events or omissions giving rise to the claim occurred in this District. EEG

has its principal place of business in this District, it is authorized to conduct business in this 

District, has intentionally availed itself of the laws and markets within this District, does 

substantial business in this District, and is subject to personal jurisdiction in this District.

FACTUAL ALLEGATIONS

The 2020 Ultra Music Festival

39. The Ultra Music Festival is an annual outdoor festival that focuses heavily on the 

performance of electronic dance music, and is typically hosted in March, in Miami, Florida. 

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40. This year, Ultra was scheduled to run from March 20, 2020 to March 22, 2020. 

Standard ticket prices ranged from $300 to $400 depending on when the tickets were purchased;

VIP tickets sold for $1,500 (collectively, the “Tickets”). 

41. On March 2, 2020, as the COVID-19 pandemic rapidly spread, EEG—in an effort 

to assuage Class members’ concerns and entice the public to continue to purchase tickets—posted 

messages to its social media accounts informing the public that the event would be occurring in 

“just a few weeks” and that EEG was preparing the festival grounds for the event.1

42. EEG has disclosed in public court filings that “tens of thousands of tickets to the 

2020 event were sold.” (ECF No. 1-2, ¶8.) If one conservatively estimates that 30,000 people 

purchased Tickets to Ultra 2020—a fraction of the approximately 55,000 people who purchased 

tickets to the 2019 festival—and each purchased the least expensive ticket, Plaintiffs and the Class 

paid at least $9,000,000 for 2020 Ultra tickets.

43. As news of the pandemic spread, however, the City of Miami and EEG entered into 

negotiations in order to reach agreement on postponing the event.2

44. Following days of extensive negotiations, on March 4, 2020, the City and EEG

agreed that the 2020 festival would be “postponed” indefinitely.3 In other words, EEG cancelled 

the 2020 festival just days after it assured Class members that Ultra 2020 would go forward.

45. On March 6, 2020, EEG announced that due to a purported “directive” from the 

City of Miami—rather than by mutual agreement of the parties, as was the case—the Ultra festival 

 1 https://twitter.com/ultra/status/1234624700271284232 (last visited May 7, 2020). 

2 https://www.miamiherald.com/news/local/community/miami-dade/downtownmiami/article240878956.html (las visited May 7, 2020). 

3 Id.

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would be postponed until March 26 to March 28, 2021.

4 EEG posted the following message to its 

Twitter account: 

46. On March 10, 2020, in response to mounting requests for refunds for the cancelled 

2020 festival, EEG issued a statement confirming it will not provide refunds for 2020 ticket 

purchases notwithstanding that by postponing the festival until 2021, it effectively cancelled the 

festival’s 2020 iteration.

5

 4 https://www.miamiherald.com/news/local/community/miami-dade/downtownmiami/article240878956.html (last visited May 7, 2020). 

5 https://www.miamiherald.com/news/local/community/miami-dade/downtownmiami/article241050006.html (last visited May 7, 2020). 

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47. EEG’s statement also informed Plaintiffs and Class members that tickets instead 

would “be honored at either the 2021 or 2022 Ultra Miami event, at your option. You will have 30 

days to choose which Ultra Miami event you want to attend.”6

48. EEG, however, cannot be certain that future festivals will occur. 

49. Florida recently reported more than 15,000 COVID-19 cases in a single day, the 

largest single-day increase of COVID-19 cases in any state since the beginning of the pandemic.

7

50. Ultra Music Festival’s location, Miami, is the new epicenter of the COVID-19 

pandemic,

8 and with hospitals at 95% capacity, Miami’s mayor is considering another lockdown.9

51. Florida’s high number of COVID-19 cases make an event of Ultra’s size unlikely 

to occur in the near future, even next year.

52. Indeed, upon information and belief, it has been alleged that EEG has failed to 

procure the necessary permits from the City of Miami to hold the festival at Bayfront Park in 2021, 

and has also not entered into contracts with all performers expected for the festival in 2021. 

53. In other words, EEG cannot possibly know, let alone be confident, that Ultra will 

occur in 2021 or 2022, but has insisted on retaining millions of dollars Class members paid for a 

festival that may never occur.

54. EEG thus has, in effect, shifted the burden of the COVID-19 pandemic onto 

festivalgoers like Plaintiffs and the Class, individuals who in these desperate times may sorely 

need the money they paid to EEG for a festival that never occurred.

 6 Id.

7 https://www.nbcmiami.com/news/local/miami-dade-mayor-gimenez-holds-press-conferenceto-address-coronavirus-outbreak/2261451/ (last visited July 16, 2020). 

8 Id.

9 https://wsvn.com/news/local/miami-dade/suarez-warns-about-possible-future-lockdown-asflorida-breaks-1-day-record-in-covid-19-deaths/ (last visited July 16, 2020). 

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55. EEG has done so by hiding behind its illusory Ticketing Terms and Conditions, 

including an arbitration provision EEG undoubtedly will rely on in hopes of permanently 

insulating itself from classwide liability.

Ticketing Terms and Conditions

56. EEG allows for consumers to purchase different tiers of tickets. An advertisement 

listing the different tiers of admission is included below.

57. In order to purchase Tickets, EEG requires purchasers to agree to its Ticketing 

Terms and Conditions (“TT&C”), a copy of which are attached hereto as Exhibit A. The TT&C 

include several provisions relevant to this action.

58. The TT&C contain a choice-of-law provision that states: “This Agreement shall be 

governed and construed in accordance with the laws of the state of Florida, notwithstanding any 

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contrary choice-of-law principles, and all claims relating to or arising out of this Agreement or 

breach thereof.”

59. The TT&C also state that “[a]ny proceeding to enforce [the] arbitration agreement

must be brought in the state court or, if jurisdiction permits, in the U.S. District Court in the 

Southern District of Florida with venue lying in Miami-Dade County.”

60. The TT&C also include a provision that EEG “may, in its sole and absolute

discretion elect to either issue a full or partial refund to Purchaser, not issue any refunds, or 

reschedule the Event.” 

61. The provision also states: “[i]f Issuer elects to issue a refund, the Ticket purchaser 

of record shall be refunded an amount up to the face value of the Ticket(s) only. If Issuer elects to 

reschedule the Event for a future date, You shall not be entitled to a refund. Under no 

circumstances shall You be entitled to a refund of any shipping, handling or other processing and 

service fees.” 

62. Through the refund provision, EEG purports to reserve to itself the right to retain 

any and all monies paid for tickets regardless of whether EEG elects to put on the festival, 

essentially (and impermissibly) rendering its obligations under the TT&C illusory and the 

agreement itself an unenforceable unilateral option contract. 

63. EEG also purports to reserve to itself the right to “modify, add, remove, 

supplement, amend, update or revise any of [the] terms and conditions, without advanced 

notification to” the customer. EEG failed to provide any limitations on its right to modify the 

contract with consumers, thereby rendering the TT&C illusory and void in their entirety. 

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CLASS ALLEGATIONS

64. Plaintiffs bring this action individually and on behalf of a nationwide class pursuant 

to Federal Rules of Civil Procedure 23(a), 23(b)(2), and/or 23(b)(3), defined as follows:

All persons who purchased tickets to the 2020 Ultra Music Festival.

65. In the alternative, Plaintiffs bring this class action on behalf of the following State 

Subclasses:

The Florida Class

All Florida residents who purchased tickets to the 2020 Ultra Music Festival.

The Washington Class

All Washington residents who purchased tickets to the 2020 Ultra Music Festival.

The California Class

All California residents who purchased tickets to the 2020 Ultra Music Festival.

66. Excluded from the Class(es) are: (a) Defendant; (b) Defendant’s affiliates, agents, 

employees, officers and directors; and (c) the judge assigned to this matter, the judge’s staff, and 

any member of the judge’s immediate family. Plaintiffs reserve the right to modify, change, or 

expand the various class definitions set forth above based on discovery and further investigation

67. Numerosity: Upon information and belief, the Class is so numerous that joinder of 

all members is impracticable. While the exact number and identity of individual members of the 

Class are unknown at this time, such information being in the sole possession of Defendant and 

obtainable by Plaintiffs only through the discovery process, Plaintiffs believe, and on that basis 

allege, that the Class consists of tens of thousands of people. The number of Class members can 

be determined based on Ultra’s records.

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68. Commonality: Common questions of law and fact exist as to all members of each 

Class. These questions predominate over questions affecting individual Class members. These 

common legal and factual questions include, but are not limited to

a. Whether EEG should be required to provide refunds for its 2020 festival;

b. Whether the contract between EEG and Plaintiffs and the Class contained an 

impermissible unlimited ability to modify the agreement unilaterally;

c. Whether the contract between EEG and Plaintiffs and the Class was illusory 

and void; and

d. Whether EEG was unjustly enriched by its conduct. 

69. Typicality: Plaintiffs have the same interest in this matter as all Class members, 

and Plaintiffs’ claims arise out of the same set of facts and conduct as the claims of all Class 

members. Plaintiffs’ and Class members’ claims all arise out EEG’s uniform conduct and 

statements.

70. Adequacy: Plaintiffs have no interest that conflicts with the interests of the Class,

and are committed to pursuing this action vigorously. Plaintiffs have retained counsel competent 

and experienced in complex consumer class action litigation. Accordingly, Plaintiffs and their

counsel will fairly and adequately protect the interests of the Class. 

71. Superiority: A class action is superior to all other available means of fair and 

efficient adjudication of the claims of Plaintiffs and members of the Class. The injury suffered by 

each individual Class member is relatively small compared to the burden and expense of individual 

prosecution of the complex and extensive litigation necessitated by EEG’s conduct. It would be 

virtually impossible for members of the Class individually to effectively redress the wrongs done 

to them. Even if the members of the Class could afford such individual litigation, the court system 

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could not. Individualized litigation increases the delay and expense to all parties, and to the court 

system, presented by the complex legal and factual issues of this case. Individualized rulings and 

judgments could result in inconsistent relief for similarly-situated individuals. By contrast, the 

class action device presents far fewer management difficulties, and provides the benefits of single 

adjudication, economy of scale, and comprehensive supervision by a single court.

VIOLATIONS ALLEGED

COUNT I

CONVERSION

(On Behalf of the Nationwide Class or, in the alternative, the State Subclasses)

72. Plaintiffs incorporate by reference each of the allegations contained in paragraphs 

1 through 71 of this Complaint.

73. Plaintiffs and the Class are entitled to a refund of monies paid in exchange for 2020 

Ultra tickets because the festival was cancelled.

74. Plaintiffs and the Class have demanded that EEG return their property.

75. EEG has refused to issue refunds to Plaintiffs and the Class, and thus has, 

unlawfully and without authorization, assumed and exercised dominion and control over that 

property to the exclusion of, or inconsistent with, the rights of Plaintiffs and the Class.

76. EEG’s conversion has damaged Plaintiffs and the Class in the amount that they paid 

for 2020 festival tickets. 

77. Plaintiffs and the Class are entitled to recover the amount each paid to EEG for 

their tickets, as well as attorneys’ fees, costs and interest.

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COUNT II

UNJUST ENRICHMENT

(On Behalf of the Nationwide Class or, in the alternative, the State Subclasses)

78. Plaintiffs incorporate by reference each of the allegations contained in paragraphs 

1 through 71 of this Complaint.

79. Plaintiffs and the Class conferred a direct benefit on EEG by purchasing Tickets.

80. EEG knowingly and willingly accepted and enjoyed the benefits conferred on it by 

Plaintiffs and the Class.

81. EEG voluntarily accepted and retained these benefits, with full knowledge and 

awareness that, as a result of EEG’s conduct, Plaintiffs and the Class would not, and did not, 

receive the benefit of their bargain that had been represented by EEG and that reasonable 

consumers would expect.

82. EEG’s retention of these benefits is unjust and inequitable.

83. As a direct and proximate result of EEG’s unjust enrichment, Plaintiffs and the 

Class are entitled to recover the amount each paid to EEG for their Tickets, attorneys’ fees, costs 

and interest. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs, on behalf of themselves and the Class, respectfully request that 

this Court:

A. Determine that the claims alleged herein may be maintained as a class action under 

Rule 23 of the Federal Rules of Civil Procedure, and issue an order certifying the 

Class as defined above;

B. Appoint Plaintiffs as the representative of the Class and their counsel as Class 

Counsel;

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C. Award actual damages and equitable monetary relief to Plaintiffs and the Class 

and/or order EEG to return to Plaintiffs and the Class the amount each paid to EEG; 

D. Award pre-judgment and post-judgment interest on such monetary relief;

E. Grant appropriate injunctive and/or declaratory relief, including, without limitation, 

an order that requires EEG to issue refunds to any member of the class who requests

a refund;

F. Award reasonable attorneys’ fees and costs; and

G. Grant such further relief that this Court deems appropriate.

JURY DEMAND

Plaintiffs, on behalf of themselves and the putative Class, demand a trial by jury on all 

issues so triable.

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Dated: July 20, 2020 Respectfully submitted, 

/s/Adam M. Schachter 

ADAM M. SCHACHTER 

Florida Bar No. 647101 

aschachter@gsgpa.com

ANDREW J. FULLER 

Florida Bar No. 1021164 

afuller@gsgpa.com

GELBER SCHACHTER & GREENBERG, P.A. 

1221 Brickell Avenue, Suite 2010 

Miami, Florida 33131 

Telephone: (305) 728-0950 

Bryan L. Clobes (pro hac vice)

CAFFERTY CLOBES MERIWETHER 

& SPRENGEL LLP 

205 N. Monroe St. 

Media, PA 19063 

Telephone: (215) 864-2800 

Facsimile: (215) 964-2808 

Email: bclobes@caffertyclobes.com

Daniel O. Herrera (pro hac vice)

CAFFERTY CLOBES MERIWETHER 

& SPRENGEL LLP 

150 S. Wacker Dr., Suite 3000 

Chicago, Illinois 60606 

Telephone: (312)782-4880 

Facsimile: (312)782-7785 

Email: dherrera@caffertyclobes.com

Joseph G. Sauder (pro hac vice)

SAUDER SCHELKOPF LLC 

1109 Lancaster Ave. 

Berwyn, PA 19312 

Telephone: (888) 711-9975 

Facsimile: (610) 421-1326 

Email: jgs@sstriallawyers.com

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Marcus W. Corwin

Florida Bar No. 0764647

CORWIN LAW

MARCUS W. CORWIN, P.A.

6001 Broken Sound Parkway NW, Suite 404

Boca Raton, FL 33487

Telephone: (561) 482-3636

Facsimile: (561) 482-5414

Email: mcorwin@corwinlawfirm.com

Counsel for Plaintiffs and the Class

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