I Sark Ohanian, Esq.

(SBN 208905)
CARPENTER, ZUCKERMAN & ROWLEY, LLP
2 8827 West Olympic Boulevard
Beverly Hills, California 9021 1-3613
3 Telephone: (310) 273-1230
Fax: (310) 858-1063
4 E-mail:
sark@czrlaw.com
5
Attorneys for Plaintiff,
6 AJA OXMAN
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT - UNLIMITED
10
AJA OXMAN, an Individual,
CASE NO.
12
Plaintiff, . .
Plaintiff Aja Oxman s Complaint for
Damages for:
JUSTIN BIEBER, an Individual; DWAYNE
1. Assault and Battery
15
PATTERSON, an Individual; and DOES 1
2. Intentional Infliction of Emotional
through 50 inclusive,
Distress
16
3. Negligence
Defendants.
17
18
19 Plaintiff, Aja Oxman, alleges as follows:
20
21 GENERAL ALLEGATIONS
22 1. Plaintiff, Aja Oxman (Plaintiff), is, and at all times herein mentioned was, an
23 individual residing in Kauai County in the State of Hawaii.
24 2. Defendant, Justin Bieber (Defendant Bieber), is, and at all times herein
25 mentioned was, an individual residing in the County of Los Angeles, State of
Carpenter, 26 California.
Zuckerman,
& Rowley, 27 3. Based on information and belief, defendant, Dwayne Patterson (Defendant
LLP
28 Patterson), is, and at all times herein mentioned was, an individual residing in
COMPLAINT
I the County of Los Angeles, State of California.
2 4. At all times herein mentioned, Dwayne Patterson was acting as the bodyguard for
3 Justin Bieber.
4 5. At all times herein mentioned, Defendant Patterson was the employee and/or
5 agent of Defendant Bieber, acting in the course and scope of his employment
6 and/or agency with Defendant Bieber.
7 6. At all times herein mentioned, Defendant Bieber was, and still is, an entertainer
8 and considered a public figure.
9 7. The incidents giving rise to the subject action occurred on November 20, 2013 at
10 or near the public areas of Shipwreck Beach, a public beach in Kauai, Hawaii.
ii 8. The true names and capacities of defendants sued herein as Does 1 through 50,
12 inclusive, are unknown to Plaintiff Oxman, who therefore sues such defendants
13 by such fictitious names pursuant to Code of Civil Procedure

474. Plaintiff
14 Oxman is informed and believes, and thereon alleges, that each of the fictitiously
15 named defendants is responsible in some manner for the occurrences alleged and
16 that Plaintiffs damages were proximately caused by those defendants. Plaintiff
17 will seek permission of this court to amend this complaint to show such true
18 names and capacities when they have been determined.
19 9. Each reference in this complaint to Defendant, Defendants or a specifically
20 named defendant shall include reference to all defendants, including fictitiously
21 named defendants.
22 10. Plaintiff is informed and believes, and thereon alleges, that at all times relevant
23 hereto, each defendant was the officer, director, owner, managing agent, agent,
24 employee, or employer of each of the co-defendants and in doing the acts
25 hereinafter mentioned, each defendant was acting within the scope of its authority
Carpenter, 26 and as such officer, director, owner, managing agent, agent, employee or
Zuckerman,
& Rowley. 27 employer with the permission and consent of the co-defendants, and that said acts
LLP
28 of each defendant were ratified by said defendants co-defendants.
2
COMPLAINT
1 FIRST CAUSE OF ACTION
2 ASSAULT AND BATTERY
3 (Against All Defendants, and Each of Them.)
4 11. Plaintiff Oxman re-alleges each and every allegation contained in paragraphs 1
5 through 10, and by this reference incorporates said paragraphs as though fuiiy set
6 forth herein.
7 12. On or about November 20, 2013, Plaintiff Oxman was lawfully in the public area
8 of Shipwreck Beach in Kauai, Hawaii, and engaged in his profession by, inter
9 alia, taking photographs of Defendant Bieber for commercial sale.
10 13. Defendant Bieber was staying at a nearby hotel and walked over to Shipwreck
11 Beach with his entourage, including one of his bodyguards, Defendant Patterson.
12 14. Defendant Bieber climbed up the cliff at Shipwreck Beach and jumped into the
13 ocean. Plaintiff Oxman and other celebrity photographers took photos of
14 Defendant Bieber as he did so.
15 15. Once Defendant Bieber got out of the ocean, he noticed that Plaintiff Oxman was
16 present and taking photos of Defendant Bieber.
17 16. At that point, Defendant Bieber pointed in Plaintiff Oxmans direction and, in
18 essence, ordered Defendant Patterson to go do his dirty work for him.
19 17. As Defendant Bieber pointed at Plaintiff Oxman, he was heard by independent
20 witnesses telling Defendant Patterson to go get his memory card and do
21 whatever you have to do to get that card.
22 18. Defendant Patterson complied with Biebers orders and did, in fact, do whatever
23 he thought he had to do to get Plaintiff Oxmans camera and memory card.
24 19. Defendant Patterson approached Plaintiff Oxman, physically grabbed Plaintiff
25 Oxman in a choke-hold and lifted him into the air by his neck. Defendant
Carpenter, 26 Patterson then slammed Plaintiff Oxman down onto a parked vehicle.
Zuckerman,
& Rowfey, 27 20. Defendant Bieber authorized, encouraged and enjoyed the beating of Plaintiff
LLP
28 Oxman by his bodyguard.
3
COMPLAINT
1 21. Witnesses heard Plaintiff Oxmans cries for help during the attack, but neither
2 Bieber, nor anyone else in his entourage, extended any compassion or assistance
3 to Plaintiff Oxman.
4 22. Defendant Patterson attacked Plaintiff Oxman in Biebers presence until another
5 photographer approached with a cell phone in an attempt to video record
6 Defendant Pattersons actions. At that point, Defendant Patterson let go of
7 Plaintiff Oxman and stated, while laughing, you think Im that stupid to get
8 caught by one of your little phone cameras?
9 23. At that point, Defendants Patterson and Bieber destroyed Plaintiff Oxmans
10 expensive camera, took his keys & memory card and walked away.
11 24. Although Defendant Patterson wasnt that stupid to get caught by one of the
12 little phone cameras, justice was served as he was charged and convicted with
13 various crimes as a result of this vicious and unwarranted attack.
14 25. By engaging in the above-referenced conduct, Defendants acted in a physically
15 threatening manner, with the intent of creating fear and apprehension in Plaintiff
16 Oxman of a harmful and offensive contact, and Plaintiff Oxman felt so
17 threatened.
18 26. The aforementioned abusive and reprehensible conduct was done without consent
19 or justification, and without any provocation by Plaintiff Oxman.
20 27. The aforementioned abusive conduct was intended to and did result in serious
21 physical and emotional injury to Plaintiff Oxman, including, without limitation,
22 severe injuries to his body, including, without limitation, his head, face, and
23 limbs, as well as severe emotional distress and anxiety. Said conduct also resulted
24 in the loss or damage of personal property.
25 28. As a factual and legal result of defendants actions, Plaintiff Oxman suffered
Carpenter, 26 injuries, all to Plaintiff Oxmans general damages in a sum to be proven at the
Zuckerman,
& Rowley, 27 time of trial.
LLP
28 29. As a further factual and legal result of the aforesaid acts of Defendants, Plaintiff
4
COMPLAINT
Oxman has required and/or for an unpredictable period in the future will require
2 the services of doctors, physicians, surgeons, nurses, hospitals and like related
3 professional services, including drugs, medication and x-rays, and he has and
4 continues to incur medical and incidental expenses which will be shown
5 according to proof
6 30. As a further factual and legal result of the acts of defendants, Plaintiff Oxman
7 was prevented from attending to his usual occupation and has suffered loss of
8 present and future earnings in an amount according to proof at trial. Plaintiff
9 Oxman additionally has suffered impairment and loss of present and future
10 earning capacity, also in an amount accordingly to proof at trial.
11 31. Defendants committed the acts alleged herein intentionally, with the intent to
12 cause injury to Plaintiff Oxman and with a conscious disregard of the rights and
13 safety of Plaintiff Oxman and others. Further, the foregoing intentional acts
14 subjected Plaintiff Oxman to cruel and unjust hardship in conscious disregard of
15 Plaintiff Oxmans rights. As a result of the foregoing, Plaintiff Oxman is entitled
16 to punitive damages against defendants in an amount according to proof.
17 32. Plaintiff Oxrnan seeks reasonable damages to sufficiently compensate him for his
18 injuries and loss.
19
20 SECOND CAUSE OF ACTION
21 INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
22 (Against All Defendants, and Each of Them.)
23 33. Plaintiff Oxman re-alleges each and every allegation contained in the above
24 paragraphs 1 through 32, and by this reference incorporates said paragraphs as
25 though fully set forth herein.
Carpenter, 26 34. Plaintiff Oxman is informed and believes and thereon alleges that the
Zuckerman,
& Rowley, 27 aforementioned acts of Defendants, and each of them, were outrageous and were
LLP
28 engaged in by Defendants intentionally and maliciously, for the purpose of
5
COMPLAINT
1 causing Plaintiff Oxman to suffer humiliation, mental anguish and emotional and
2 physical distress.
3 35. Defendants conduct in confirming and ratifying that conduct was done with the
4 knowledge that Plaintiff Oxmans emotional and physical distress would thereby
5 increase, and was done with a wanton and reckless disregard of the consequences
6 to Plaintiff Oxman.
7 36. As a factual and legal result of the aforementioned outrageous conduct by
8 defendants, Plaintiff Oxman suffered humiliation and severe mental and
9 emotional distress, all to Plaintiff Oxmans damage in an amount exceeding the
10 minimumjurisdiction of this Court according to proof at time of trial. Said
11 mental and emotional distress includes, but is not limited to, suffering shock,
12 insomnia, humiliation, embarrassment, shame, tentativeness, fear, an inability to
13 concentrate, worry and anxiety for an extended period of time after the incident
14 as a result of defendants conduct. Said distress is particularly present when
15 plaintiff engages in his occupation.
16 37. As a further factual and legal result of the aforesaid outrageous conduct by
17 defendants, Plaintiff Oxman has required and/or for an unpredictable period in
18 the future will require the services of doctors, physicians, surgeons, nurses,
19 hospitals and like related professional services, including drugs, medication and
20 x-rays, and he has and continues to incur medical and incidental expenses which
21 will be shown according to proof.
22 38. As a further factual and legal result of the acts of defendants, Plaintiff Oxman
23 was prevented from attending to his usual occupation and has suffered loss of
24 present and future earnings in an amount according to proof at trial. Plaintiff
25
Oxman additionally has suffered impairment and loss of present and future
Carpenter, 26 earning capacity, also in an amount accordingly to proof at trial.
Zuckerman,
& Rowey, 27 39. Defendants committed the acts alleged herein intentionally, with the intent to
LLP
28 cause injury to Plaintiff Oxman and with a conscious disregard of the rights and
6
COMPLAINT
safety of Plaintiff Oxman and others. Further, the foregoing intentional acts
2 subjected Plaintiff Oxman to cruel and unjust hardship in conscious disregard of
3 Plaintiff Oxmans rights. As a result of the foregoing, Plaintiff Oxman is entitled
4 to punitive damages against Defendants, and each of them, in an amount
5 according to proof.
6 40. Plaintiff Oxman seeks reasonable damages to sufficiently compensate him for his
7 injuries and loss.
8
9 THIRD CAUSE OF ACTION
10 NEGLIGENCE
11 (Against All Defendants, and Each of Them.)
12 41. Plaintiff Oxrnan re-alleges each and every allegation contained in the above
13 paragraphs 1 through 40, and by this reference incorporates said paragraphs as
14 though fully set forth herein.
15 42. Defendants owed to Plaintiff Oxman a duty of reasonable care regarding, infer
16 a/ia, Defendants interaction with photographers and other members of the
17 public.
18 43. On November 20, 2013, Defendants so negligently handled themselves and
19 interacted with the public in that Plaintiff Oxman was threatened with physical
20 harm and battered.
21 44. On and prior to the date of this incident, Defendants negligently hired, trained
22 and/or retained Defendant Patterson to provide security services as the employee
23 and/or agent or each other Defendant.
24 45. The aforementioned negligence by the Defendants resulted in serious physical
25 and emotional injury to Plaintiff Oxman, including, without limitation, severe
Carpenter, 26 injuries to his body, including, without limitation, his head, face, and extremities,
Zuckerman,
& Rowley, 27 as well as severe emotional distress and anxiety.
LLP
28 46. As a factual and legal result of defendants actions, Plaintiff Oxman has suffered
7
COMPLAINT
1 injuries, all to Plaintiff Oxmans general damages in a sum to be proven at the
2 time of trial.
3 47. As a further factual and legal result of the aforesaid acts of Defendants, Plaintiff
4 Oxman has required and/or for an unpredictable period in the future will require
5 the services of doctors, physicians, surgeons, nurses, hospitals and like related
6 professional services, including drugs, medication and x-rays, and he has and
7 continues to incur medical and incidental expenses which will be shown
8 according to proof.
9 48. As a further factual and legal result of the acts of defendants, Plaintiff Oxman
10 was prevented from attending to his usual occupation and has suffered loss of
11 present and future earnings in an amount according to proof at trial. Plaintiff
12 Oxrnan additionally has suffered impairment and loss of present and future
13 earning capacity, also in an amount accordingly to proof at trial.
14 49. Plaintiff Oxman seeks reasonable damages to sufficiently compensate him for his
15 injuries and loss.
16 WHEREFORE, Plaintiff Oxman prays for judgment against defendants as follows:
17 1. AS TO THE FIRST CAUSE OF ACTION
18 a. For general damages in an amount to be proven at trial;
19 b. For special damages in an amount to be proven at trial; and
20 c. For exemplary and punitive damages according to proof at the time of trial.
21 2. AS TO THE SECOND CAUSE OF ACTION
22 a. For general damages in an amount to be proven at trial;
23 b. For special damages in an amount to be proven at trial; and
24 c. For exemplary and punitive damages according to proof at the time of trial.
25 3. AS TO THE THIRD CAUSE OF ACTION
Carpenter, 26 a. For general damages in an amount to be proven at trial; and
Zuckerman,
& Rowley, 27 b. For special damages in an amount to be proven at trial.
LLP
28 /1/
8
COMPLAINT
4. AS TO ALL CAUSES OF ACTION
a. For costs of suit incurred herein;
b. For prejudgment interest; and
c. For such other and further relief as the Court deems just and proper.
DATED: August 19, 2014 C1 ZUCKERMAN & ROWLEY, LLP
By:
AJA
2
.3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Carpenter,
Zuckerman,
& Rowley,
LLP
9
COMPLAINT