Gary Bloom sues talent agents, Powerful Story Lines LLC, and others over The Money Tree and The Last Door screenplays

What was filed

The complaint is Document 1 in No. 4:26-cv-40237, U.S. District Court for the District of Massachusetts, file-stamped October 14, 2026 (77 pages). The plaintiff is Gary M. Bloom of Malden, Massachusetts, who signs as a pro se plaintiff and a member of the Massachusetts bar. The defendants are Jennifer Sims; Tiffany Richer, also known as Tiffany Atwood; RPM Talent Agency; Michael A. Levine; Powerful Story Lines LLC, a New Mexico limited liability company; Shelley A. Piña, doing business as Golden Pineapple Management; John Edward Keough; and Manny Jae Media, LLC, of Worcester, Massachusetts. Bloom demands a jury trial. (Compl. pp. 1, 3 to 5, 74, 77.)

The complaint designates the case as related under Local Rule 40.1(g) to Bloom v. Campbell, No. 1:24-cv-10339-RGS (D. Mass.), which it says is stayed because the sole defendant there, William James Campbell III, has a pending Chapter 13 case, No. 1:26-bk-11090-VK (Bankr. C.D. Cal.). Campbell is not a defendant in the new case. The complaint says Bloom sought to join six of the new defendants in the earlier case, leave was denied, and he filed the new action to protect expiring limitations periods. (Compl. pp. 1 to 3.)

The copyright counts

The complaint alleges that The Money Tree, a feature-length screenplay, was registered under Registration No. PAu004062783 on October 14, 2020, and under Registration No. TXu002242158 on March 7, 2021, the second listing Chris Esper as sole claimant and Esper and Campbell as authors. It alleges that on October 17, 2025, Esper assigned Bloom, for $10, all of his right, title, and interest in the screenplay, including the right to sue for past infringements. It also alleges that Bloom is a co-author and co-owner of The Last Door, Registration No. PAu004191778. (Compl. paras. 25 to 26, 77, 225, 297 to 298, 302; pp. 8, 36 to 37, 49 to 50.)

Count V, under 17 U.S.C. 501, alleges that on September 12, 2024, Levine prepared a version of The Money Tree that reproduces about 90 percent of the Campbell and Esper draft and whose title page credits Campbell as writer and Levine with a "Polish"; that a copy went to Sims; and, on information and belief, that Powerful Story Lines LLC and its members or agents emailed copies to parties who responded to its website. On information and belief, it alleges that Sims distributed copies of The Last Door without Bloom's authorization. It also alleges that Sims and Levine are vicariously and contributorily liable for the LLC's acts, that RPM Talent Agency is liable for Sims's acts, and that the infringement was willful. It pleads timeliness under 17 U.S.C. 507(b) and registration before infringement under 17 U.S.C. 412, and seeks damages or statutory damages under 17 U.S.C. 504 and an injunction under 17 U.S.C. 502. A separate part of Count V alleges, on information and belief, that Piña reproduced and distributed, or caused Campbell to reproduce and distribute, copies of both screenplays, citing 17 U.S.C. 106(1) and (3). (Compl. paras. 296 to 310; pp. 48 to 52.)

Count XIV, under 17 U.S.C. 1202, is against Powerful Story Lines LLC, Sims, RPM Talent Agency, and Levine. It alleges that the website credit "WRITTEN BY WILLIAM JAMES CAMPBELL" and the 2024 title page, which omits Esper and bears a "Copyright 2023" notice, are false copyright management information as defined in 17 U.S.C. 1202(c), and that Powerful Story Lines LLC, Sims, and Levine knowingly provided and distributed it in violation of 17 U.S.C. 1202(a), with intent to induce, enable, facilitate, or conceal infringement. The website credit is alleged directly; the distribution of copies bearing the title page is alleged on information and belief. It alleges that Sims acted as a partner or agent of RPM Talent Agency. It seeks actual damages or statutory damages per violation under 17 U.S.C. 1203(c)(3)(B). (Compl. paras. 393 to 401; pp. 73 to 74.)

Other counts and relief

The other twelve counts are fraud, breach of contract, promissory estoppel, unjust enrichment, tortious interference, civil conspiracy, aiding and abetting fraud, breach of fiduciary duty, unfair and deceptive acts under M.G.L. c. 93A, an accounting, defamation, and intentional infliction of emotional distress. The prayer seeks compensatory damages, treble damages under M.G.L. c. 93A, statutory damages under 17 U.S.C. 504(c) and 1203(c)(3)(B), an accounting, removal of The Money Tree and two other projects from Powerful Story Lines LLC's website and marketing, and injunctions against marketing the projects without Bloom's consent. (Compl. pp. 42 to 77.)