(rage tof 19) £eBh @ AHR200 @ 1390 SC: 044 12/ 2018 TRIAL: 04 / 27 7 2018 OSC: 10/ 28/ 2019 LAWRENCE P. GRASSINI—SBN 49046 LARS C, JOHNSON—SBN 205712 BRIAN HONG ~ SBN 217932 Flu EDs GRASSINI, WRINKLE & JOHNSON supa Korte 20750 Ventura Boulevard, Suite 221 intv at 8 ANOIES: ‘Woodland Hills, CA 91364-6235 Te (B18) 3481717 OCT 2.8 2016 "ax: (818) 348-7921 Email: mail@grassinilaw.com ae rae Dery Attorneys for Plaintifis AZ He L ppc SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT STEVE DE CASTRO, CARLY DE caseno: BCG 39107 CASTRO, ‘ Plaintiff, ' | COMPLAINT FOR PERSONAL INJURIES AND DAMAGES - NEGLIGENCE: ws : PECULIAR RISK; BATTERY; ASSA Hee INTENTIONAL INFLICTION OF THOMAS E. SIZEMORE; PARAMOUNT | EMOTIONAL DISTRESS; LOSS OF PICTURES CORPORATION; CAST & CONSORTIUM (CREW TALENT SERVICES, LLC; CAST & CREW ENTERTAINMENT ‘SERVICES, LLC; VIACOM, INC.; and DOES | through 100, Inclusive, etal, Defendants. COMES NOW, Psinifs STEVE DE, CASTRO axl CARLY DE CASTRO, and for ‘causes of action against Defendants THOMAS E. SIZEMORE, PARAMOUNE, & CORPORATION, CAST & CREW TALENT SERVICES, wg BARE & aig ENTERTAINMENT SERVICES, LLC, VIACOM INC., and DOES 1 and each of them, allege as follows: ee ‘s oe 2 90" Wd LzD0 ones zeo0e8F 2! Hes : Ba88 | : 8883 6 ‘COMPLAINT FOR PERSONAL INJURIES AND DAMAGES NEGLIGENCE, PECULIAR RISK, BATTERY; ‘ASSAULT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: LOSS OF CONSORTIUM Paget 1 - Deo = 1668065540 ~ Doo ype = OFSwre (rage 2 of 19) Sew rxaue n 2 13 4 15 16 7 18 19 20 au 2 4 2 28 FIRST CAt ACTION (For Negligence Against All Defendants) 1 ‘The true names and capacities, whether corporate, associate, individual, or otherwise, of defendants, DOES 1 through 100, inclusive, are unknown to plaintiffs, who therefore sue said defendants by such fictitious names. Each of the defendants designated herein as a DOE is negligently or otherwise legally responsible in some manner for the events and ‘happenings herein referred to and caused injuries and damages proximately thereby to the plaintiffs, as herein alleged. Plaintiffs will ask leave of Court to amend this Complaint to show their true names and capacities when the same have been ascertained, 2. At all times herein mentioned, defendants, and each of them, were either the agents, servants, employees, permissive users, joint venturers, successors in interest assigns and subsidiaries, each of the other, and at all times pertinent hereto were acting within the course and scope of their authority as such agents, servants, employees, permissive users, joint venturers, ‘successors in interest, assigns and subsidiaries, or were ;pendent contractors hired by each of the remaining defendants to perform work wii h was likely to involve a special risk of harm to others which such defendants knew or should have known: that the work was likely to involve this risk or had some other legal relationship one to each other so ast impose legal, vearous liability on each defendant forthe injury-producing acts ofthe other defendants 3. Atal times herein mentioned, Defendants THOMAS E, SIZEMORE and DOES | through 100, inclusive, and each of them, were and ae residents ofthe County of Los Angeles, State of California. 4 AL all times, herein “mentioned, Defendants CAST & CREW TALENT SERVICES, LLC, and DOES 1 through 100, inclusive, and cach of them, were and are business entities duly organized and existing under and by virtue of the laws of one of the fifty (50) states. 5. At alll times herein mentioned, Defendants CAST & CREW TALENT SERVICES, LLC, and DOES | through 100, inclusive, and each of them, were and are business entities authorized to do busines, and doing business in the State of California. _2. ‘COMPLAINT FOR PERSONAL INIURIES AND DAMAGES - NEGLIGENCE; PECULIAR RISK; BATTERY: ‘ASSAULT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: LOSS OF CONSORTIUM ‘ech 1 Pageb 2 = Doo ID = 1669065540 - Doo Type = Om6. Atall times herein mentioned, Defendants CAST & CREW ENTERTAINMENT SERVICES, LLC, and DOES 1 through 100, inclusive, and each of them, were and are business entities duly organized and existing under and by virtue of the laws of one of the fifty (50) states. 7. Atal times herein mentioned, Defendants CAST & CREW ENTERTAINMENT SERVICES, LLC, and DOES | through 100, inclusive, and each of them, were and are business entities authorized to do business, and doing business in the State of California. 8 At all times herein mentioned, Defendants PARAMOUNT PICTURES CORPORATION and DOES | through 100, inclusive, and each of them, were and are business entities duly organized and existing under and by virtue of the laws of one of the fifty (50) states, 9. At all times herein mentioned, Defendants PARAMOUNT . PICTURES CORPORATION and DOES | through 100, inclusive, and each of them, were and are business entities authorized to-do business, and doing business in the State of California, 10. Atal times herein mentioned, Defendants VIACOM INC., and DOES 1 through 100, inclusive, and cach of them, were and are busines entities duly organized and existing under and by virtue ofthe Jaws cof one of the fifty (50) states. 1. Atall times herein mentioned, Defendants VIACOM INC,, and DOES 1 through 100, inclusive, and each of them, were and are business entities authorized to do business, and doing business in the State of California. 12, At all times herein mentioned, defendants, and each of them, supervise, financed, created, managed, operated, maintained, and controlled the production of a cable television series entitled “Shooter.” 13, Atall times herein mentioned, defendants, and each of hem, were the registered owners, operators, lessees, and lesors of a certain automobile and a allies herein mentioned, were operating said automobile with the knowledge, permission, and consent, each ofthe other. 14, Atall times herein mentioned, Plaintiff STEVE DE CASTRO, was a film industry professional working primarily wa. stontnan through his loan-out corporation, Stevie D Corp. 3 ‘COMPLAINT FOR PERSONAL INIURIES AND DAMAGES - NEGLIGENCE; PECULIAR RISK; BATTERY; ‘Dost 4 Faget 3 - Doo ID = 1669065540 - Doe type = ommR(rage 4 of 29) 1 15. On or about July 6, 2016, Plaimiff STEVE DE CASTRO was at the Agua Dulce 2 || Airport in the County of Los Angeles, State of California working as a stuntman on the remote 3 || location for the filming and production of “Shooter”, at whi time and place the defendants, and 4 || each of them, so negligently, carelessly, recklessly, and unlawflly, owned, drove, maintained, operated, entrusted, and controlled said vehicle, so negligently, carelessly, recklessly, and unlawfully managed, produced, directed, controlled, operated, supervised and produced the filming and production of the above referenced film production and otherwise so negligently ‘conducted themselves, so as to cause such vehicle to collide with Plaintiff STEVE DE CASTRO thereby directly and legally causing the injuries and damages to plaintiffs as hereinafter 10 |] enumerated. u 16. On or about July 6, 2016, during the aforementioned production, defendants, and 12 || cach of them, so negligently, carelessly, recklessly and unlawfully planned, prepared, directed, .d, retained, 14 || supervised and controlled participants, and otherwise so negligently conducted themselves, so as 15 || to cause Plaintiff STEVE DE CASTRO to directly and legally suffer the injusies and damages 16 || hereinafter enumerated. : 13 || controlled, managed, operated, and supervised such activities, and negligently Wa 17. The injures and damages desorbed rein were proximately caused by the : 18 |] intoxication of Defendants THOMAS E. SIZEMORE and DOES 1-100. , 19 18. The injuries and damages described herein were proximately caused by the willful : 20 || and unprovoked physical acts of aggression of Defendants THOMAS B. SIZEMORE and DOES ar |] 1-100. cei : i a 19. On or about July 6, 2016, Defendant THOMAS E. SIZEMORE became 23 || intoxicated knowing he would operate a motor vehicle and then operated said motor vehicle in a 24 reckless, dangerous manner knowing that Plaintiff STEVE DE CASTRO and other cast members 25 || and bystanders were lying on the ground nearby. The actions of Defendant THOMAS E. SIZEMORE, as alleged herein, were willful, wanton, intentional, malicious, oppressive, despicable, vile, contemptible and mote done in conscious distegard for the rights and safety of 4 “COMPLAINT FOR PERSONAL INJURIES AND DAMAGES - NEGLIGENCE; PECULIAR RISK; BATTERY; | 1 ASSAULT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: LOSS OF CONSORTIUM oot 1 Paget 4 = Bee TD 5690 Doe ype = OTEK(eage 5 of 19 : e ° | 1 || plaintiff, thereby justifying an award of exemplary damages against Defendant THOMAS E. 2 || SIZEMORE in an amount to be determined at the time of trial. | 3 20. As adirect and legal result of the acts and omissions of the defendants, and each of them, plaintiff was rendered sick, sore, lame, disabled, and disordered, both internally and fright, shock, pain, discomfort, and anxiety. The exact nature and extent of said injuries are not known to plaintiff who will pray leave of Court to insert the same when they are ascertained. Plaintiff does not at this time know the exact duration of permanence of said injuries, but is ' extemally and suffered, among other things, numerous internal and extemal injuries, severe | informed and believes, and thereon alleges, that some-of the said injuries are reasonably certain r 10 ||, tobe permanent in character, j n 21. Asa further direct and legal result of the acts and omissions of the defendants, ! 12 |) and each of them, plaintiff has been forced to incur expenses for medical care, X-rays, and | 13 ]] laboratory costs during the period of plaintfPs disabilities and is informed and believes and 14 || thereon alleges, that plaintiff will in the future be forced to incur additional expenses of the same 15 || nature, all in an amount which is at present unknown, ‘Pant wi pray leave of Court to show 16 the exact amount of said expenses at the time of trial. 1 22. Prior to the occurrence of this accident, plaintiff was an able-bodied individual, 18 || but since said accident plaintiff has been unable to engage filly in his occupation, and is 19 || informed and believes, and thereon alleges, that he will be incapacitated and unable to perform 20 |] his usual work for an indefinite period of time in the future, all to plaintfP's damage in an 21 || amount which is t present unascertained, Plaintiff will pray leave of Court to show the total |! \ 22 || amount of loss of earnings atthe time of trial. B 23, Plaintiff has been generally ‘damaged in an amount within the jurisdictional limits 24 || ofthis Court, 25 5 ‘COMPLAINT FOR PERSONAL INJURIES AND DAMAGES - NEGLIGENCE, PECULIAR RISK, BATTERY; ‘ASSAULT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: LOSS OF CONSORTIUM ‘Dock 1 Page 5 - Boa HD = 1669065540 ~ Doo Type = OTA1 SI USE OF ACTION or Peculiar Risk Against All Defendants) 24. Plaintiffs hereby repeat, reallege, and replead all of the First Cause of Action herein, and incorporate the same by reference, as though set forth in full at this place. 25. The activities of the defendants as described above, involved presence, work and activities including stunts, staged firefights, and involving the dangerous operation of various Vehicles, and other work and activities that posed extreme risk of severe harm, and were foreseeably likely to involve a special risk of harm to others, including Plaintiff STEVE DE | CASTRO. Corn e aun 10 26. — Atall times herein, the defendants, and each of them, knew or should have known, 11 || that such presence, work, and activities were likely to involve such special risk. 8 27, Defendants, and each of them, failed to use reasonable care or to take specific 13 || safety measures appropriate to the danger to avoid such risk, “4 28, Such failure on the part of defendants, and each of them, was a diret, legal, and 15 |} proximate cause of and substantial factor in causing the injuries and damages to plants as 16 |} described herein, 7H ; ” 18 ‘THIRD CAUSE OF ACTION 19 (For Battery Against All Defendants) 20 29, Plaintiffs hereby repeat, reallege, and replead all of the First and Second Causes 21 || of Action herein, and incorporate the same by reference, as hough set forth in full at this place, 2 30. Defendants, and each of them, willfully and unlawfully used, and caused to be : 23 || used, force and violence upon Plaintiff STEVE DE CASTRO, with the intent to harm plaintiff 24 || and without plantif’s consent 25 31, Asa direct and legal result of the acts and omissions of the defendants, and each 26 || of them, Plaintiff was placed in great fear for hs life and physical well-being, and suffered non- 27 || consensual, harmful and offensive contact. ~6. ‘COMPLAINT FOR PERSONAL INJURIES AND DAMAGES — NEGLIGENCE; PECULIAR RISK, BATTER) ‘ASSAULT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: LOSS OF CONSORTIUM qi ‘Dock 4 Pageh 6 - Doe 1D = 1669065540 - boa type(rage 7 of 19) wow aueu 10 u 2 13 4 15 16 "7 18 19 21 22 2B 4 32. At such time and place defendants, and each of them, committed a willful end ‘unprovoked physical act of aggression upon the plaintiff by intentionally and with conscious disregard for causing injury and harm to the plaintiff running over his prone body with a motor vehicle, 33. At all times mentioned herein, the officers, directors, and/or managing agents of defendants, and each of them, directed, authorized and ratified the above described battery, willful and unprovoked physical act of aggression and conduct of their agents and employees which conduct was likely to result in serious injury to cast members and bystanders including plaintiff. Defendants and each of them ratified the injurious conduct of Defendants THOMAS E. SIZEMORE and DOES 1-100 by not terminating him from the production when they discovered that he had severely injured and nearly killed the plaintiff by the above described battery and ‘willful and unprovoked physical act of aggression upon the plaintiff and by failing to di Defendants THOMAS E. SIZEMORE and DOES 1-100 under such circumstances. A, Asa direct out legal result ofthe ats and omissions ofthe defendants, and each of them, pla ff was rendered sick, sor, lame, isabled, and disordered, both intemally and extemally and suffered, among other things, numerous iniemal and extemal injures, severe fright, shock, pain, discomfort, and anxiety. The exact nature and extent of said injuries are not known to plaintiff who will pray leave of Court to insert the same when they are ascertained, Plaintiff does not at this time know the exact duration of permanence of said injuries, but is informed and believes, and thereon alleges, that some of the said injuries are reasonably certain to be permanent in character. 35. As a further legal result of the acts and omissions ofthe defendants, and each of them, plaintiff has been forced to incur expenses for medical care, X-rays, and laboratory costs uring the period of plaintiff's disability, and is informed and believes, and thereon alleges, that plaintiff will in the future be forced to incur additional expenses of the same nature, all in an amount which is at present unknown. Plaintiff will pray leave of Court to show the exact amount of said expenses at the time of trial. 7 ‘COMPLAINT FOR PERSONAL INJURIES AND DAMAGES - NEGLIGENCE, PECULIAR RISK; BATTERY, "ASSAULT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: LOSS OF CONSORTIUM(ago 8 of 15) Cea nnnen 10 u 2 13 4 15 16 a7 19 20 2 2 23 24 25 36. Prior to the occurrence of this incident, plaintiff was an able-bodied individual, bbut since said incident, plaintiff has been unable to engage fully in his occupation, and is informed and believes, and thereon alleges, that he will be incapacitated and unable to perform. his usual work for an indefinite period of time in the future, all to plaintiff's damage in an amount which is at present unascertained, Plaintiff will pray leave of Court to show the total ‘amount of loss of earings and/or earning potential at the time of trial. 37. Plaintiff has been generally damaged in an amount within the jurisdictional of this Cour. FOURTH CAUSE OF ACTION (For Assault Against All Defendants) 38. Plaintiffs hereby repeat, reallege, and replead all of the First, Second, and Third Causes of Action herein, and incorporate the same by reference, as though Set forth in full at this place, ' : ee 39. Defendants, and each of them, intended to cause and did cause Plinff STEVE DE CASTRO, to suffer apprehension of an immediate harmful contact without plaintiff's ee 40, At such time and lace defendens, and each of them, commited a wifi and tanprovoked physical act of, agresion pon the plsinti by intentionally and with conscious disregard for causing injury and harm to the plaintiff running over his prone body with a motor vehicle. 41. tall times mentioned herein, the officers, directors, and/or managing agents of defendants, and each of them, directed, authorized and ratified the above described assault, willful end unprovoked physical tet of aggression and conduct oftheir agents and employees which conduct was likely to result in serious injury to cast members and bystanders including plaintiff, Defendants and each of them ratified the injurious conduct of Defendants THOMAS E. SIZEMORE and DOES 1-100 by not terminating him from the production when they discovered teeny : 8 ‘COMPLAINT FOR PERSONAL INIURIES AND DAMAGES - NEGLIGENCE; PECULIAR RISK; BATTERY: ‘ASSAULT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: LOSS OF CONSORTIUM ‘ rit | i ‘Dock 4 Pagob € - Bos 2D = 1669065540 - boa Type = ormrage 9 of 15) wee wane un 10 u 2 1B 4 1s 16 ” 18 19 20 21 2 23 4 25 26 Py that he had severely injured and nearly killed the plaintiff by the above described assault and willful and unprovoked physical act of aggression upon the plaintiff and by failing to discipline Defendants THOMAS E. SIZEMORE and DOES 1-100 under such circumstances. 42, Asa direct and legal result of the acts and omissions of the defendants, and each of them, plaintiff was rendered sick, sore, lame, disabled, and disordered, both internally and extemally and suffered, among other things, numerous intemal and external injuries, severe fright, shock, pain, discomfort, and anxiety. The exact nature and extent of said injuries are not known to plaintiff who will pray leave of Court to insert the same when they are ascertained, Plaintiff does not at this time know the exact duration of permanence of said injuries, but is informed and believes, and thereon alleges, that some of the said injures are reasonably certain to be permanent in character. 43, Asa further legal result of the acts and omissions of the defendants, and each of them, plaintiff has been forced to ineur expenses for medical care, X-rays, and laboratory costs, daring the period of plaintiffs Aisabitity, an é informed and believes, and thereon alleges, that Plaintiff will inthe future be, foreed to incur additonal expenses of te same nature, all in an amount which is at present unknown. Plaintiff wil pray lave of Court to show the exact amount of said expenses a the time of tral eee 44. Prior to the ccgurrence of this incident, plaintiff was an able-bodied individual, but since said incident, pleiniet bas been able 1 engage fully his occupation, and is informed and believes, and thereon alleges, that he will be incapacitated and unable to perform his usual work for an indefinite period of time in the future, all to plaintif’s damage in an amount which is at present unascertined. Plaintiff will pray leave of Court to show the total amount of loss: of earings andlor eaming potential atthe time of tral, 45. Plaintiff has been generally damaged in an amount within the jurisdictional limits of this Court. ‘ : ; 9 ‘COMPLAINT FOR PERSONAL INIURIES AND DAMAGES - NEGLIGENCE, PECULIAR RISK; BATTER" ‘ASSAULT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: LOSS OF CONSORTIUM oeage 20 of 19) carr aue 10 2 1B 14 1s 16 7 18 19 20 a 2 23 4 FIFTH CAUSE OF ACTION (For Intentional Infliction of Emotional Distress Against All Defendants) 46. Plaintifis hereby repeat, reallege, and replead all of the First, Second, Third, and Fourth Causes of Action herein, and incorporate the same by reference, as though set forth in full atthis place, 47. Defendants, and each of them, negligently, carelessly, recklessly, intentionally, and unlawfully conducted themselves so as to directly and legally cause the injuries and damages to plaintiffs as alleged herein. 48. The acts and omissions of the defendants, and each of them, as described herein ‘were engaged in by defendants, and cach of them, with a willful and knowing disregard of the rights and safety of Plaintiff STEVE DE CASTRO. Defendants, and each of them, acted with reckless disregard’of the probability that plaintiff would suffer severe emotional distress. The conduct of defendants, and each of them, was so extreme and outrageous so as to exceed all bounds ofthat usuelly tolerated in decent and civilized society. 49. As a direct and legal result of the acts and conduct of defendants, and each of thom, pit hes been caused o, and did sue, and continues to sft severe and permanent ‘emotional and mental distress and anguish, humiliation, embarrassment, fright, shock, pain, iscomfort and anxiety. The exact nature and extent of said injuries is presently unknown to plaintiff who will pray leave of Court to assert the same when they are ascertained, 50. Asa direct and legal result of the acts and omissions of defendants, and each of them, plaintiff was rendered sick, sore, lame, disabled and disordered, both intemally and externally, and suffered, emong other things, a severe laceration to the face, severe fright, shock, pain, discomfort and anxiety. The exact nature and. extent of said injuries are not knowm to the Plaintiff, who will pray leaye of Court to assert the same when they are ascertained. Plaintiff does not at this time know the exact duration or permanence of said injuries, but is informed and believes, and thereon alleges, that some of the suid injuries are reasonably certain to be permanent in character. 10 ‘COMPLAINT FOR PERSONAL INJURIES AND DAMAGES — NEGLIGENCE; PECULIAR RISK; BATTERY, ‘ASSAULT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: LOSS OF CONSORTIUM(rage 11 of 29) wane un 10 ul 2 13 14 15 16 7 18 19 20 a 2 23 24 ~ 6 Sl. Asa further legal result of the acts and omissions of the defendants, and each of them, plaintiff has been forced to incur expenses for medical care, X-rays, and laboratory costs during the period of plaintif?'s disability, and is informed and believes, and thereon alleges, that plaintiff will in the future be forced to incur additional expenses of the same nature, all in an amount which is at present unknown. Plaintiff will pray leave of Court to show the exact amount of said expenses at the time of trial. 52. Prior to the occurrence of the incident, plaintiff was an able-bodied individual, but since said incident, plaintiff has been unable to engage fully in his occupation, and is informed and believes, and thereon alleges, that he will be incapacitated and unable to perform his usual work for an indefinite period of time in the future, all to plaintiffs damage in an amount which is at present unascertained. Plaintiff will pray leave of Court to show the total amount of loss of eamings at the time of trial. we 53. Plaintiff has been generally damaged in an amount within the jurisdictional limits ofthis Cout, ae : ‘SIXTH CAUSE OF ACTION (For Loss of Consortium Against All Defendants) : rfiem Against A) 54, Plaintiff CARLY DE CASTRO hereby repeats, realleges, and repleads all of the Fist, Second, Third, Fourth and Fifth Causes of Action herein, and incorporates the same by reference, as though se forth in fll a this place 55, Plaintiff CARLY DE CASTRO is the wife of Plaintiff STEVE DE CASTRO and at all times herein. mentioned has been a loving and, dutiful wife to him. 56. As a result of, the acts and omissions of the defendants, and each of them, as alleged herein, Paint CARLY DE CASTRO hasbeen depived ofthe cre, comfort society, ‘companionship, and conjugal benefits of her marrage to Plaintiff STEVE DE CASTRO, and that Joss of cons continues. W ‘COMPLAINT FOR PERSONAL INJURIES AND DAMAGES — NEGLIGENCE; PECULIAR RISK; BATTERY; ‘ASSAULT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: LOSS OF CONSORTIUM ‘Deck 4 Faget 13 ~ Doe 1D = 1669065540 ~ Doe ype © OTMER(age 12 of 29) eeras Sewmraunun tt B 4 15 16 7 18 19 a 4 25 6 7 2B 57. The nature and extent of seid loss is not filly ascertained. Plaintiff CARLY DE CASTRO will seek leave of Court at the time of trial to show the total amount of loss. 58, Plaintiff CARLY DE CASTRO has been generally damaged in an amount within the jurisdictional limits of this Court. WHEREFORE, Plaintiffs STEVE DE CASTRO and CARLY DE CASTRO pray judgment against Defendants THOMAS E. SIZEMORE and DOES 1 through 100, inclusive, and cach of them, as follows: 1. For general damages in an amount within te jutidictionl limits ofthis Court; 2. Formedical expenses and related items of expense, aocording to proof; 3. Forloss ofearnings, according to proof 4, Forloss fearing capacity, according to proof, 5. Foreosts of suit incured herein; 6. Forprejudgment intrest according to proof 7. For punitive and exemplary damages according to proofs and 8 For schol and futher ei the Court may deem just and proper. WHEREFORE, Plainiffs STEVE DE CASTRO and CARLY DE CASTRO pray judgment against Defendants PARAMOUNT, PICTURES CORPORATION, CAST & CREW TALENT SERVICES, LLC, CAST & CREW ENTERTAINMENT SERVICES, LLC, VIACOMINC, and DOES I tzough 10, inclusive, and each of thems follows: 1. For general damages in an amount within the jurisdictional limits of this Cou 2 Formetical expenses and related items of expense, according to pron; 3. Forloss of earings, according to proof 4. Forloss of earning capacity, according to proof; 5. For costs of suit incured herein; 6 For prejudgment interest according to proof andage 13 of 29) 1 7, For such other and further relief as the Court may deem just and proper. DATED: October 18, 2016 GRASSINI, WRINKLE & JOHNSON A Law Corporation RENCE P. GRASSINI ttomeys for Plaintiffs 10 nN 12 : ‘ 13 4 15 7 7 ! 18 19 20 : a i 2 | ca ” 25 1B ‘COMPLAINT FOR PERSONAL INTURIES AND DAMAGES - NEGLIGENCE; PECULIAR RISK; BATTERY; ‘ASSAULT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: LOSS OF CONSORTIUM . ‘Boot 1 Pages 33 ~ Doo 1D = 1668065540 - oo Type = OTHER ¥(age 26 of 19) i + H Tree tr aaa Oscars | [LAWRENCE P. GRASSINI SBN’ 49006 GRASSINI, GRINKLE & JORNSON 20750 Ventura Boulevard, Suite 221 Woodland #ills,ca 91364-6235 ‘razrwonewo: (818)348-1717 — raxno: (818) 348-7921 supa it ED. tems Plaintiff: 6 ly De Ca: Noninty af ras Annales SUPERIOR COURT OF CALFORMA counv or LoS Angeles smervonsel1i Nr Hail Street OCT 28 2016 civamapccceLos Angeles, CA 90012 sara CANE Bini e eassy nose cour snagrepepumonct CASENAVE. DE CASTRO v. THOMAS E. SIZEMORE, et al CIVIL CASE COVER SHEET Complex Gave Designation Tae Ce Unites” Cjtumitoa Cy counter CJ soinder BC639107 eur, aroun Fed wh fist oppearance by defendant [008 exezeus 925.000) SEE 800s ess (Cal, Rulos of Cour, rule 3.402) a ems 1-6 below must be complled (eee instrucions on page 2) [7 Ghezk one Box below forthe case type thal best describes this ease: : Ato Ter ‘Contct Provisionlly Complex Ct Ligation Auto 22) CC otesenotcocractnaranty (8) (Cal. Rules of Cour, res 2400-2402) Clune na cea rate 3.740 calctions (0) & ‘AniirusyTrade regulation (03) ‘ | ona ljuyProper her cation CConstction cee (10) | Scoeosraht Ferrin © icone asbestos (04) Other contact (37) [© Seaurtesitigation (28) erect tabity 20) Real Propery, TE ensronnenarToxiston 2) (media matpracic (45) - [Jeminert comsinnerse [i esuraee eovrage cians arising tom ne [ilonerptppwo a ‘irdemnaton (8) shove ales provionaly comet cate ‘Non-PHPDAWD (Other) Tort A wrongtut eviction 3) ‘types (41) (J susiesstocuntar tosiness pracsce cor) L—] Other reat property (26) Enforcement of Judgment Lolewarigns (0) Uniawtul Detainor (Enforcement of judgment (20) (owtenaton 19) CJcanmecit (1) iscallzneous Civil Complaint (J rrus 16) (PRestoentat e229 Caron [1 intetiectus property (19) Cong: ae) [1 other comsint ina specified above) (42) Pretessional negigence (25) Judicial Review Miscellaneous Civil Petition orn rox ours tt 05) (Jaceet frst (05 [Parmer and carporate governance (21) Employment ([)Pettion re: arbitration award (11) (] Otrer petition (not speciiod above) (43) Woon teins (35) ut of mandate (02 Cloteremsiymencisy 7" tec fica even (8) : ‘ 2 Thiscase [Tis DJ isnot complex under ule’ 3.400 of the California Rules of Cour. ifthe case is complex, mark the equiing exceptional judicial menagement; Large number of separately represented partes! :d. [) Lerge riumber of winesses >. Clemons roton practice raising dificult or novel :e. [~] Coordination wih lated actions pending in one or more courts ‘sues that willbe tmia-consuriing tovesalve | in other counties, states, or countres, or ina federal court ' c. (—) Substantial amount of documentary evidence —_¢, [} Substantial postjudgment judicial supervision . Remedi cought (check al that app): 2. [x] moritary b. (_—) nanmeinetary, declaratory or injunctive raiot c. punitive 1. Number of causes of action (specity). Negi; Perr sk; Busey, Asal; earl inten of ote srs; Las of conetam Trscase (ie Gi) isnot acass action suit pee e Date: October 24, 2016 " LAWRENCE P. GRASSTNT — ay rave z = NOTICE. ‘Plaintiff must fe this cover sheat withthe frst paper Hed in the action or proceeding (except small claims cases or cases fied ie Pest Ce Fant ote, er Wt ra atsns Cae) Re Coun) Faeioe ay eu ‘in sanctions. TORT this case is complex under rue 3.400 el seq. ofthe Calfomia Rules of Cou, you must serve a copy ofthis cover sheet on all “other partes tothe action or proceeding, Unless tis is eotecions case under ue 3.70 or a cmon cases cover sheet wil bo usd for tistical purposes on "SeCancletcren CIVIL CASE COVER SHEET, Tangs eon a TO NS stir i ‘San seth : ‘ooh 4 Pagee 14 ~ Doe ID = 1669065540 ~ Doc ype = OTEERGage 35 of 29) INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET tends ‘To Psinttis and Others Filing First Papers. If you are fing a frst paper (for example, a complain) in a civl case, you must complete anf, alang wth your fst paper, the Givi Case Cover Shoot contained on page 1. Ths informaton wil be used to comple ‘talstics about the types and numbers of cases fled. You must complete items 1 tcugh 6 on the sheet. Initem 1, you must check ‘one bo forthe ease fype that best describes the case, ifthe case fs boh a general anda mare specif ype of case listed in tem 1, heck the mote spec one. I the case as muitple causes of action, check he box thal best nda the primary cause of acon ‘Tovassst you mn completing the sheet, exams of he cates that belong under each case typo inom 1 are povided bol. A cover ‘sheet must be fled only wth your ita paper. Faire fo flea cover sheet withthe fst paper led in acl case may subject a party, ts ‘course, er both to sanctions under res 2.30 and 3.220 ofthe Calfomia Rules of Coun “To Parties in Rute 3.740 Collections Cases. A”callcions case" under rule 3740's defined as an ackon for recover of money owed ina sum stated to be certain thats not more than $25,000, exciusive of interest and ettomeys fees, arising fom transaction in which property, Senices, or money was acqUired on ered. A eollecione caso does not Include an acion eaaking the folowing: (tort {domages, 2) puniive damages, (3) recovery of real propery, recovery of personal property, or (6). prejudgment wit of stachment. + The identifeaton of case as & rule 3.740 coflecions case on ths form means that t wil be exempt from the general ime-orservice requirements and case management rues, unless a deerant fies a responsive pleading, Araie 3.740 colectons case willbe subject to ve requements for sence and obtaining a judgment in rue 3.740. ‘To Partias in Complex Cases. In complex cases only, partis must also use the Civil Case Cover Sheot to designate whethor the case s complex. Ifa plaintf believes the case is complox under ule 8400 ofthe Calera ules of Cour, this must be indicated by ‘Completing the appropiate boxes in lems 1 and 2 a paint designates a case as comple, the cover sheet must be served wth the ‘omplanton al partes tothe action. A defendant may fle and serve no later than the ime ofits st appearance a jender inthe plains designation, a counter-designaton that the case is rol complex, or, if he paint has made no desgnalin, a designation that tho casos complex ‘CASE TYPES AND EXAMPLES Auto Tort Contact Provisionally Complex Civil Litigation (Ca ‘Ao (2}-Persoal my Propety, Bach of ConsacsWananty (05) Rule of Court Rules 3400-3400) ‘Daragerongil Deas Broge ofRaalaose “Anscus rade Regulation (03) ‘Uninsured Moterist (48) the eee ‘Construction Detect (10) ‘ace vast sins conn to) helen Wass Tet (0) Soeutenn aomete anachWarerty eecSeler Ironing es Simca crtsnon, gaia, Senet on one iets yy Waray 11) Insurance Coverage Cine (Personal Voter Brea of Coniectwacen * fas tom provisional complex Prpeny Damapenrongt oa) Ccalacions eg, may oned.cpen” 1: | aso ype lated ado) () oak eeu ee rceme mr Aestes 0) Cecio cuaguic baum ' | ~ EMorenenotdadement ‘atest Poser ny” " 1 ata anette ‘wong beat ' ie (ot privy Prost Labi (ntabostosor —§ "comple (18). \ Gunkicion of Judgment roe i ‘oxt/onrcanania) 22) + + fs Sobsegation ‘ ‘domes fang) I ‘Medical Malpas) «oy, other verge 5. Sitesi suegere ‘iaeat precees «Othe Cana ‘aiiristave Agency Award Pryicaee s Sygeers » *"GoneaclPratd ae (rot ust taxes) cae Senate feaneae ‘OherGorkactDsiue ||" |: retorts of Ey of Wabracioe asi propery an “bodgrent on Unpais Totes ‘one PIPDANO G2) | ‘rien! Oomainvierse (ter nficerent of Judgment Premaes sity ep.sip "Candermaton (1) Case : or Wig Eten (3) Iuscellneous Gil Complaint Intent Bly juryPOWD Other Real Propary ea. cut iaeyian RICO naval Bay Wurg-D Vid Posen tel Peery (Otter Contant (not species Intentional efieon of + Maange Forse t on von Emotanl Dts ‘Oe: Rea Pcp (nl emirest” —| Dalaran Rael Only [Negigeat Inficton of ‘domain, tandlrdfenant, or " Ooty fron Emofonal Distess treasure) ferret ther IPOD ‘Way Dtanae : : ica Non PUPDAND (Othe) Tor + ‘conmeras(H) _ Di comm ‘BuchaseTonUnlor Buness Resdenal 2) cea bentae Pract (7) rigs (08) ne Sse nose! ‘eon oanarconpey) : Cour Rts (eg tsctimestin, hugs, check is lem; ofbanize teacsecreccs ea ra ‘ite rest fret ot ‘eva as Commerc or Roser) te naessmend (08) ude Review! mers an Sop Defamation fe, slander, ed ‘scet Fete (08) caer Pamca pet cai 3) Petter Re: aration Aad) on Fraud (18) Witt Mandate (02) Cha Hssoment Jnelectul Proper (19) ‘Wrt-Adminstatve anders (eee gpm ‘Petessona Napigene (25) ‘Wi-Mancdmes of Lied Court Dependent Adult Legal tpracica Case Abuse SE Other Professional Nabiac Wet-Oter Linked Cout Case ecton Contest (ol mecca rege) bed ? Pete oF Nee Chango “Gtner Non: PPDAWD Ton (35) ‘Other ducal Review (36) Penton fortatet ton tae 1 Employment ‘Reet ie Ofer tant "prongt!Terinaton (6) cal-aber a ca 9 “San oon Re ST CIVIL CASE COVER SHEET _ raat ‘Doct 1 Fagot 28 - Doe HD = 1669065540 - Doo Type = OTHERrage 16 of 29) at e ° are GERD a Se, Ea pcan 107 CIVIL CASE COVER SHEET ADDENDUM AND ‘STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) This form is required pursuant to Local Rule 2.3 in all new civil case flings In the Los Angoles Superior Gourt. lem |. Check the types of hearing and fil in the estimated length of hearing expected for this case: sun TruaL? ves CLASS ACTION? [—] YES LIMITED CASE?[_] YES TWEESTINATED FOR TRIALS__["~]Hours/[ x ]oayS: tem Il. Indicate the correct cistriet and courthouse location (4 steps ~ If you checked "Limited Case", skip to Item Il, Pg. 4): Step 1: After frst completing the Civil Case Cover Sheet form, fnd the main Chil Case Cover Sheet heading for your case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected. ‘Step 2: Check one Superior Court type of action in Column BB below which best describes the nature ofthis case, ‘Step 3: In Column G, cic the reason for the court lacalion choice that angles to the type of action you have ‘checked. For any exception to the court location, see Local Rule 2.3. ie ‘Applicable Reasons for Choosing Courthouse Location (see Column C below) Courthouse Pe ar 3 geen cn ene rs ee x eerie 1 sa eee occ ie aeieeem one & [Bitton tte potemands weaned er caesar, "40, Lenton ef tabor Commissener ‘Step 4: Fil in te information equebted 0 pe z ; 7 Civ Case Cover Sheet Eat ‘Category No. era (Check ony one) 5 ‘Aso 2) [1 7109 tar Veto Pana syne OsmageNrergta Deak 3 [ems [arto rosea anety Onsen eet - near [Cl ase ais Pty Doge : — sess 0 |) 7221 Asbestos -Persoalnjunyfitongl Death 2 Product Labity (24) |[_] 7260 Product Lsbliy (not asbestos oF txicfemvconmental) I ara wescaapncte Pyare Spee Iolury Property ‘Bamage/ Wrongful Death Tor EB | Modcatmaracico 4) 1) grasa cine Prtestioal Heath Gare Malracce te z I ara remedy, nanan, he q TheyPeoety, - .(C—1.47230,nonorat secty mr Pepery Daragetengtl Dead (eg.. | 4.4 & Damage Worl | Meme". [LIAS timabanenaiatr ween [a B | _ Wiongtteviion (93) | [Abbas Woh vton os , 26 } [TE habia tanga recone 26 © | cxernearopony as) |=) xe bite’! 26 hoon on i Hepéiy terran somo, atorsorant econ) | 2,6. | PRseronapa-conercat] (Taser Unoosaneromnerc tds orwenfievctind | 2.6 .d. [tiitoaneactesatn |) ngs dinate Renta etd ewer | 2.8 2] BREEN [Cones von oenerrearncone te %° _[ untantet Detainer rugs (38) | [__] A6iz2 Uniewis Detainer-Drug, 2.6. = evo, CIVIL CASE COVER SHEET ADDENDUM Toeal Rue 3 Use Arpoved 06 AND STATEMENT OF LOCATION Page 2014 Doct 2 Faget £7 - Doo TD = 1669065540 ~ Doo type = OTHERrage 18 of 39) |) 8000 omer Git Complaint (non-orUnon-complax) WoumE DE CASTRO v.THOWAS 6, STZEWORE, et a1. eon a B © hepato ‘ct cane Coe See “ype ton Reston Seo Sip Calpe (Chester) aioe ‘set Forenwo 05) |] Ast’ aset are Case 2.8, i Pettion re Arbitration (11) |] A6115 Petition to CompelConfrm/Vacate Arbiration 28. a sete wet -Adnisrtve names 2.8 % | wirermeedte re) |) aetsa wet-warcamuson tinted Coun Cse tater 2 3 feta wear Umted Cau Cate Review 2 (Otner Jucciat Review (35) |[—] 6160 Omer Wet Ktesiciat Review 2,8. g_| Patios race Repuaton2)|—T ASO Ante rade Regan Eo B | conatuctn ete e) [I] asoor consecton Detect 14248 [Cains en mss Tow |) 6006 cnt vod ass To e & | secrtostnanson ce) |] nets secures Ligation Co 128 ene ee 12.8.8, wpsaes Caaae Cs |) aus tnuance Coveageibogation ange cae or 12.5.8 TJ st Str Sate Jegrent a (Aero roatactt neanent Be xtrcomort |) A607 conersan of segment (nda mists) : 3 fade 20) |) 6140 Admiiskasve Agency Award (nt unpaid exes) as 46114 Pettion/Ceniscate for Entry of Judgment on Unpaid Tax asta oneréntceman ot Jamon Coo 7 RICO (27) (4 8033 Racketeering (RICO) Case Z 4 fste0 cecal feet ony BE | curcompams — |{ Att Mice Ree Ont arexicarssmen) Z 3 (et Spectied Above) (42) |) A6011 Other Commiréil Complaint Cae (non torinn-camplex) Pcorerance aay |) Ast1a: Partnership nd Coporate Governonce Case 2.8 (1 astat. coat Harassment. 2,29. i (2) astze Wonpac Haebsment 2a.8 © | comecpatsins va” |) Ast20 eermezendert Aut aise Cate 2.3.8 BE | Spectaastow) tes) |) asiso Eecton Cone 2 Be TH) Asi10 Patton or cnange of Namo 27. = ast Patton Rete tom Lticain tw 280448. = TF Ast00 otter cit Pettion 2.8, Ab 09 eva) CIVIL CASE COVER SHEET ADDENDUM Toca R623 Ase Arproved 0-6 AND STATEMENT OF LOCATION Page sete oct 2 Page# 48 - Doo 1D ~ 1669065540 - Doc Type = OER(rage 19 of 39) ‘SORTTIEDE CASTRO v.THONAS E. SIZEMORE, et al. [esenanaer {tomill, Statement of Location: Enter the address ofthe accident, party's residence or place of business, performance, or other circumstance indicated in tem i, Step 3 on Page 4, as the proper reason for fing inthe court location you selected, [ecness: Agua Dulce Aiport, 33638 Agua Dulce Canyon REASON: Check the appropriate bores forthe numbers shown der Cosma Cor ihe ype otactoniatyeu have seiced er | A, cavse of action arose within this Jurisdiction 1.02. 03.es6.O6. 78.10.11. Santa Clarita ica__|91390 tem IV, Declaration of Assignment: | declare under penalty of perury under the laws ofthe State of Caforia thatthe foregoing is rue ‘and comect and that the above-entted matter is properly fled for assignment to the Stanley Mosk courthouse in the Central, District of the Superior Cour of California, County of Los Angeles [Code Civ, Proc.,§ 392 et seq, and Local Rule 2.3, subd. (a). Dated October 24, 2016 & - STORNEVFLNGPART) LAWRENCE P. GRASSINI PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY, TO BE FILED IN ORDER TO PROPERLY ‘CONMENCE YOUR NEW COURT CASE: 41, Original Compiint or Petition. 2. fing a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Counc form C010, 4 iy ase Cover Sheet Aldendum and Statement of Loraon form LAGI 108, LASC Approve 03-04 (Rev. Paymertin full of the fiing fee, unless fees have been waived. 6. Assigned order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the piaintif or petitioner is a ‘minor under 18 years of age willbe required by Court in order to issue a summons, 7. Additional copies of docurrients to be conformed by the Clerk. Coples’of the cover sheet and this addendum ‘must be served along wih the summons and complaint, er other initating pleading in he case. = & TAGie 109 ev a6) CIVIL CASE COVER SHEET ADDENDUM Local Rule23 ASC Approved 02-04 AND STATEMENT OF LOCATION Page d of 4 1 oo ‘Boot 3 Faget 29 - Doo 1D = 1669065540 - Doe Type = OTIER