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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-CV-23898

JAMES “JEB” CARTY,

Plaintiff,

v.

CHEALSE SOPHIA HOWELL and 

HAUTE AGENCY, INC.,

Defendants.

________________________________/

COMPLAINT FOR DAMAGES

Plaintiff, James “Jeb” Carty (“Carty”) sues Defendants, Haute Agency, Inc. (“Haute

Agency”) and Chealse Sophia Howell (“Howell”) and states:

JURISDICTION, VENUE, AND PARTIES

1. This is an action in which the amount in controversy exceeds $75,000, exclusive of 

interest, costs, and attorneys’ fees.

2. Carty is an individual residing in Los Angeles, California. Carty is a successful 

musical artist whose songs have been streamed hundreds of thousands of times on various music 

platforms.

3. Haute Agency is a Florida corporation with its principal address in St. Petersburg, 

Florida, that promotes itself as being “a full brand development agency.”

4. Upon information and belief, Howell is an individual residing in Miami-Dade 

County, Florida, and is the sole owner, director and employee of Haute Agency.

5. Jurisdiction is proper under 28 U.S.C. § 1332(1) because Carty is a citizen of a state 

different from Haute Agency and Howell and the amount in controversy exceeds $75,000.

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6. Venue is proper pursuant to 28 U.S.C. § 1391(b)(1) because Howell resides in 

Miami-Dade County, Florida.

GENERAL ALLEGATIONS

Howell’s Misrepresentations and Execution of the Booking Agreement

7. In or around June 2022, Carty was introduced to Howell by a mutual contact.

8. To induce Carty to enter into a contract with her company, Howell misrepresented

to Carty: (i) that she had authority to represent and secure the services of internationally-renowned

recording artist Swae Lee (“Lee”); (ii) that she was legally authorized to act as a talent agent; and 

(iii) that she could arrange a European concert tour during which Carty would perform.

9. In reliance on those representations, on June 29, 2022, Carty entered into a booking 

agreement with Haute Agency (the “Booking Agreement”). A copy of the Booking Agreement is 

attached as Exhibit A.

10. Pursuant to the Booking Agreement, Carty agreed to pay $300,000 as consideration 

for Haute Agency’s arranging for and booking Carty’s appearances on a nine-city European 

concert tour, and providing certain other required deliverables relating to a recording and 

performance collaboration between Carty and Lee (the “Deliverables”). The understanding 

between Carty and Howell, acting on behalf of Haute Agency, was that $200,000 would be paid 

in consideration for the Deliverables, and the $100,000 would be paid in consideration for Haute 

Agency’s arrangement of the European tour.

11. The Booking Agreement specifies that in the event the European tour was 

cancelled, Carty “[would] be excused from payment” of the $300,000 fee and would have the 

option of a full refund from Haute Agency. Ex. A at 2.

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12. The Booking Agreement further provides that “in the event of any litigation...with 

regard to this Agreement, the prevailing party shall be entitled to receive from the other party and 

the other party shall pay all reasonable fees, costs and expenses of counsel for the prevailing party.” 

Ex. A at 3.

Carty Pays $300,000 to Haute Agency, the European Tour 

is Cancelled, and Defendants Refuse to Return Funds to Carty

13. Carty paid $300,000 to Haute Agency through two separate wire transfers of 

$200,000 (on July 1, 2022) and $100,000 (on July 5, 2022). 

14. Soon thereafter, it became evident that Howell had exaggerated and/or fabricated 

certain material information that Carty relied upon in entering into the Agreement and paying

$300,000 to Haute Agency. 

15. For example, Howell’s representation that she and Haute Agency had the authority 

to represent Lee turned out to be false, as Lee is represented by Interscope Records.

16. In addition, Howell and Haute Agency were unable to deliver on the promised 

European tour, which was cancelled on or around August 20, 2022. 

17. Because the tour was canceled, Carty demanded the return of the $100,000 he paid 

in consideration for Haute Agency’s facilitation of the tour.

18. In response, Howell, individually and on behalf of Haute Agency, stated that she 

would return the $100,000. 

19. However, as of the date of this Complaint, Howell has not returned the funds and 

has stopped responding to communications from Carty or his representatives.

20. Howell and Haute Agency also failed to provide the Deliverables required by the 

Booking Agreement, and failed to return the $200,000.

21. Carty has retained the undersigned firm to represent him in this matter.

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COUNT I

(Breach of Contract – Against Haute Agency)

22. Carty re-alleges Paragraphs 1 through 21.

23. The Booking Agreement is a valid agreement.

24. After the cancellation of the European tour, Haute Agency materially breached the 

Booking Agreement by refusing to refund to Carty the amounts he had paid. 

25. Haute Agency also breached the Booking Agreement by failing to provide all 

required Deliverables.

26. As a result of Haute Agency’s breach, Carty has suffered damages, including 

attorneys’ fees incurred in connection with his efforts to secure the return of the funds owed to 

him. 

WHEREFORE, Carty requests the Court to enter judgment in his favor and against Haute 

Agency for all damages incurred as a result of the breach, including attorneys’ fees and costs, and 

to grant such further relief as the Court deems appropriate.

COUNT II

(Fraudulent Inducement – Against Howell) 

27. Carty re-alleges Paragraphs 1 through 21.

28. To induce Carty to enter into the Booking Agreement and pay $300,000 to Haute 

Agency, Howell made several material misrepresentations.

29. At the time of the representations, Howell knew or should have known that they 

were false.

30. Carty acted in reliance on Howell’s misrepresentations and entered into the 

Booking Agreement.

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31. Howell’s misrepresentations proximately caused injury to Carty, who has suffered 

damages in the form of the $300,000 paid to Haute Agency, in addition to attorneys’ fees and costs 

incurred in connection with his efforts to secure the return of the funds owed to him.

WHEREFORE, Carty requests the Court to enter judgment in his favor and against Howell 

for all damages incurred as a result of the fraudulent inducement, including attorneys’ fees, and to 

grant such further relief as the Court deems appropriate.

COUNT III

(Unjust Enrichment – Against Both Defendants)

32. Carty re-alleges Paragraphs 1 through 21.

33. By paying the $300,000 to Haute Agency, Carty conferred a benefit upon Haute 

Agency and also upon Howell, as the sole owner, director and employee of Haute Agency and 

who received all or substantially all of the funds ultimately retained by Haute Agency.

34. Under the circumstances, it would be inequitable for Haute Agency and Howell to 

retain the benefit of these funds without reimbursing Carty.

35. Haute Agency and Howell will be unjustly enriched if they are not required to 

reimburse Carty.

WHEREFORE, Carty requests the Court to enter judgment in his favor and against Haute 

Agency and Howell for all damages incurred as a result of the unjust enrichment, and to grant such 

further relief as the Court deems appropriate.

DEMAND FOR JURY TRIAL

Pursuant to Fed. R. Civ. P. 38, Carty demands a trial by jury on all triable issues.

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Dated: November 30, 2022

s/ Alan Rosenthal

Alan Rosenthal (FBN 220833)

arosenthal@carltonfields.com

Charles Throckmorton (FBN 101203)

cthrockmorton@carltonfields.com

Carlton Fields

2 MiamiCentral

700 N.W. 1st Avenue, Suite 1200

Miami, FL 33136

Telephone: (305) 530-0050

Facsimile: (305) 530-0055

Attorneys for Plaintiff

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