Genie Harrison, SBN 163641 Amber Phillips. SBN 280107 Mary Olszewska, SBN 2687100 SIE HARRISON LAW FIRM, 23. W. GP Steet, Suite 707 cles. CA 0014 Attorneys for PLAINTIFE SUPERIOR COURT OF THE STA FOR' JANE DOF, an individual, vs. HARVEY WEINS TED WEINSI Compo san individ jon: THE WEINSTEIN CO HOLDINGS. 1.LC, a Delaware Corporation Defendants 1. PLAINTIFEJANEL Harrison Law Firm, APC. brings this action against Defendants HARVEY WEINSTEIN WEINSTEIN"), FE WEINSTE HOLDINGS, LLC (collectively * penalties. interest as allowed by law DEFENDANES" unfaysful conduct IN COMPANY. LLC, a Dekiwatre FILED Soperior Cours of Cahtorm: APC Counts of Los Seve OE 12.2018 Bent OF CALIFORNIA, IE, COUNTY OF LOS ANGELES. cue GST CVO 468 COMPLAINT FOR: (NYCHRL §§8-10 Ler sey.) Retaliation (NYCHRL §§8-10 ler hal; U1 DMPANY jon and Retention, Violation of Cal Gender Viol Civ, Codes 52.4 DE |AND FOR JURY TRIAL NATURE OF ACTION DOL CPLAINTIFF or “DOI, through her attorneys, the Genie IN COMPANY, LLG, and THE WEINSTEIN COMPANY WC"), seeking statutory, compensatory. and punitive damages Ww. bosts. attorneys fe wad other appropriate and just reliel for COMPLAINI “le Doct 1 Pagel 4 - Doo £9 = 1759601210 - Doo Type = Complasat2, PLAINTIFF is informed and believes. and based thereon alleges, that like many other Victims, WEINSTEIN lured PLAINTIFF onto his infamous casting couch in his TW olliee, into his hotel rooms, dinners, and to industry events, all in’ WC's name and paid for by TWC, where he ‘manipulated, harassed, flashed, groped, fondled, sexually battered. forcibly perlormed oral sex. sexually assaulted, and threatened PLAINTIFF'S safety and career, While these meetings were set purportedly to discuss IWC seripts and included promises of parts and opportunities in TWC°S films (which would catapult PLAIN TIFE 'S career to another level), in reality, WEINSTEIN erchestrated the meotings us a scheme to accost PLAINTIFF and to keep her silent about his sexual chuse 3. ALall times relevant. PLAINTIFF is informed and believes, and based thereon all that IWC knew PLAINTIF was a vietim of WEINS TEIN’S predatory behavior, and fucifitated and concealed i 4. DEFENDANT W INSTEIN, upon information and befiet. at all times mentioned herein resided in Now York City, New York andor LLos Angeles, California. pon information and belief, WFINSTEIN’S house was New York City. New York, although he offen travelled to and/or resided in luxury hotels including the Waldorf Astoria in Park City, Ua, the Peninsula in Beverly ills, California, and other locations. 5 Atal DEFENDANT THE WEINSTEIN COMPANY and was. until he was fired on appronimatcly October wes relevant herein, WEINSTLIN way a Director and eo-Cha 8, 2017. 6. DEFENDANTS THE WEINSTEIN COMPANY LLC and THE WEINSTUIN COMPANY HOLDINGS LLC are Delaware Limited Liability Companies whose prineiple plaves of business are in New York Ci + in the County of New York (Collectively referred to as “TWE"), TW also had an office in Los Angeles, California, at 9100 Wilshire Blvd, Beverly Hills, California 7. TC isan employer or employment ageney within the meaning of Califomia law and the New York City Human Rights Law (°NYCHRL), 8. PLAINTIFF isa professional actress who was 22 years old when she met WEINSTEIN in 2013. Atall times relevant herein, PLAINTIFE resided in New York. ity. New York, She curently ‘COMPLAINT aa Doct 1 Fago# 2 ~ Doe 1D = 1759601310 ~ Doc Type = Complaint1 | resides in Los Angeles Count California. Jane Doe is a pseudony to protect PLAINTIFE’S. privacy, ‘The California Superior Court has jurisdiction over this setion under California, 4 | Constitution Article VI, Section 10, which grants the Superior Court “or all eauses| except those given by statute t other trial courts.” 6 10, This Court has jurisdiction and venue is proper over this action as certain wrong 7 | conduct and resulting damages occurred in Los Any *s County, California 8 11. Following commencement of this action, a copy of this Complaint will be served both 9] onthe New York ty Commission on Human Rights and the Office of the Corporation Counsel of the| 10 | City of New York, thereby satisfying the notice requirements of the New York City Administrative 1 | Code, 12 OMMON B 12, In January 2015, PLAINTIFE first met WEINSTEIN during the Sundance Film Festival 14 | in Park City, Utah, at which she provided him her curd “in ease there are any opportunities for auditions. lo 13, The next day, WEINSTEIN’S TWC assistant catled PLAINTIFE and WEINSTEIN 17 | invited her to his suite at the Waldo Astoria Park City. allegedly to discuss a potential film, About 18 | vo hours into the meeting and discussions about the film project, PLAINTIFF excused hersell to use 19 | the restroom, While PLAINTTEF was sitting on the toilet, with her tights around her ankles, 20 | WEINSTEIN opened the bathroom door and walked in on PLAINTIBE, who was initially 21 | immobilized with by embarrassment ~ thinking he entered accidently ~ which quickly: changed to 22 | terror as WEINSTEIN unbuttoned his jeans. dropped his pants to the Hloor. and exposed his penis ‘while telling her “I Fike locking at sou,” “my dick is nice and hard for you,” and asking “do you like 24 | my dick?" and instructing her “let me look at yo 8 14. Despite PLAINTIFF replying “no.” WEINSTEIN moved eloser to her while 26 | masturbating Eventually he moved so close that he was towering over her an was elose enough to try 27 | to pull up her jacket and eventually ejaculated directly onty her skirt, When he was finished, pull up i 28 | masturbating. he called her “a great girl” and joked about how slat was so flan and told her that as Jong ‘COMPLAINT de Doct 1 Pageh 2 ~ Doo 1D = 1759601210 ~ Deo type = Complaint