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Bryon M Sliven, Sate Bar Number 209743 a
‘eullvan@earysullvancom “ONG
EARLY SULLIVAN WRIGHT
Guzen MeRAL “LP
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(6420 Wilshire Boulevard, 17% Floor EC 04 2017
[Los Angeles, Califorria 90048 :
‘Telephone: (323) 301-4660 es uc case dC
Facsimile: (323) 301-4676 Marlon Gomes, Depuiy
‘Attorneys for Plaintif TERRY CREWS
SUPERIOR COURT OF THE STATE OF CALIFORNIA,
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
i BC685719
TERRY CREWS, i individual, case No.
Plait, COMPLAINT FOR DAMAGES FOR:
(1) ASSAULT
* @ barteRy
Q) SEXUAL BATTERY,
ADAM VENIT, anindividual, WILLIAM | (CAL.CLV.CODE §1708.5)
‘MORRIS ENDEAVOR (8) SEXUAL HARASSMENT
ENTERTAINMENT, LLC, aDelaware | (CAL.CIV.CODE §51.9)
limited liability company, and DOES | thra | (3) GENDER VIOLENCE
25; (CAL.CIV.CODE §82.4)
(@ INTENTIONAL INFLICTION OF
Defendants EMOTIONAL DISTRESS
(7) BREACH OF FIDUCIARY DUTY
(8) NEGLIGENCE.
(0) NEGLIGENT RETENTION AND
SUPERVISION
DEMAND FOR JURY TRIAL
COMPLAINTFa
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PLAINTIFF TERRY CREWS (“Crews”) complains and alleges the following against
DEFENDANTS ADAM VENIT (“Vent”), and his employer, WILLIAM MORRIS ENDEAVOR,
ENTERTAINMENT, LLC (“WME”), and DOES 1 thru 25 (all defendants shall be collectively
referred to “Defendants
NATURE OF CASE
1. By this action, Crews, a well-known actr from the television series Brooklyn 99
and The Expendables Film series seck to hold Vent and, his employer, WME, accountable for
the Februaty 4, 2016 olatant and unprovoked sexual assault perpetrated by Venit on Crows, a
petson who Venit hac never even met before, when Vent, upon his first meeting Crews, viously
rabbed Crews” penis and testicles so hard that it caused Crews immediate pain ina blatant and
unprovoked sexual assault.
2, This sexual assault occured at an entertainment industry event where Venit was
representing WME fer whom Venit serves as high-ranking executive as head ofits highly
lucrative motion piture department and personally represents several Als clients, including,
among others, Adan Sandler, Sylvester Stallone, Eddie Murphy, Casey AMlck, Bret Rater, and
Dustin Hoffman, Altiough Crews, a WME client himself, informed his WME agent, Bred Slater
(Slater, of the sexual assault the very next day, shockingly, WME took no action a that time
against Venit for a seal assault on a WME client likely because Veni isa significant
‘maneymaker for WME, As such, WME ratified and condoned the sexual assault and therefore
‘encouraged Venits sexual predatory behavior and allowed « known sexual predator to remain at
WME to prey on other WME clients using Venit's and WME’s extraordinary power inthe
clertainment industry to conceal his misdeeds.
3, tis now time to hold Venit accountable for his sexual predatory behavior and to
hold WME accountale forts conduct in condoning, ratifying, and encouraging Verits sexual
predatory bchavior. Indeed, a message needs to be Sento those in power who abuse those over
“whom they exert infltence and conte! that abusive and sexual predatory behavio will not be
tolerate.
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PARTIES AND VENUE
4, Crewsis and at all imes relevant hereto was, an individual residing in Los
Angeles County, California, Crews is well-known actor fom the television series Brooklyn 99
and Everyone Loves Chris, and The Expendable fie series, among others.
5. Crewsis informed and believes tha Vents, and at all imes relevant hereto was,
an individual residing in Los Angeles County, California,
6 Crewsis informed and believes that WME is, and at all mes relevant hereto was,
«Delaware limite lisbility company dang business in Los Angeles County, California, with a
rincipal place of business at 9601 Wilshire Boulevard, Third Floor, Beverly Hills, California. At
all relevant ies, Veni was employed by WME as its head of motion picture department and
‘Crews is informed and belive that Veni has an ownership interest in WME,
7. The identities of Defendants named herein as DOES 1 to 25 are presently unknown
and are therefore sued by their fictitious names. When the identities of said Defendants become
known, Crews wil sek leave af cour to inser those trve names and identities.
8 Crewsis informed and believes that each Defendant herein, inclusive of but not
limited to DOES | 1025, sand tall times herein relevant was the agent, employe, joint
‘entre, alter ego, stocestr in interest licensee, servant and partner ofeach and every other
Defendant, and as such was and is responsible forthe ation and inaction ofeach and every other
Defendant as alleged herein, Said Defendants and each of them knew of and approved and
encouraged, or therafer ratified, the conduct, action, and inaction of each and every other
Defendant which gives rise to ibility to Crews, and as such each and every Defendant diretly
and proximately caused Crews’ damages, and is responsible for them, as having acted in
furtherance ofthe action and inaction alleged herein
JURISDICTION AND VENUE
9. Pursusnt to Aticle VI, Section 10 ofthe California Constitution, subject mater
jutisicton is properin the Superior Court of California forthe County of Los Angeles
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10, Pursuant to Civil Procedure Code sections 395.5, venue is proper inthe Superior
Court of California fer the County of Los Angeles because this is where Venit committed the
sexual assault on Crews.
GENERAL ALLEGATIONS,
A. WME Is One Of The Most Powerful Cé [he Entertainment Industry And
Veni Is A Senor Executive At WME,
11, WMBis one of the largest and most powerfil companies in the entertainment
industry with its headquarters in Los Angeles and operating throughout the world, WME was
formed in 2009 through a merger ofthe Wiliam Moris Agency, a talent agency founded in 1898,
and th upstert Endeavor Talent Agency, founded in 1995, which was singled out by The New
York Times for its roputation for “ferocity and barely bridled ambition.” Since then, WME has