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INTHE STATE COURT OF GWINNETT COUNY, STATE OF GEORGIA Mm SUSAN BERNECKER, Individually and as the Exccutrix of the Estate of JOHN BERNECKER, Deceased, Plaintiff, STALWARTFILMS, LLC, ‘TWD PRODUCTIONS Vill, LLC, AMC FILM HOLDINGS LLC, AMC NETWORK ENTERTAINMENT, LLC, ‘AMC NETWORKS, INC., LARRY TENG, POWDERED DRINK PRODUCTIONS, INC., ‘TOM LUSE, TELLTALE FILMS, INC., JEFFREY F. JANUARY, JANUARY LOUNGE PRODUCTIONS, LLC, MATTHEW GOODWIN, MONTY SIMONS, MONTSTER ACTION, INC., AUSTIN AMELIO, JOHN DOE CORPORATIONS 4-2, Defendants '8¢ 00435-1 Civil Action No, JURY TRIAL DEMANDED COMPLAINT Plaintiff Susan Bernecker brings this action for wrongful death on behalf of her son, John ‘Bemecker, and as the duly-appointed Exccutrix of his Estate, against Defendants Stalwart Films, LLC, TWD Productions VII, LLC, AMC Film Holdings, LLC, AMC Network Entertainment, LLC, AMC Networks, Inc, Larry Teng, Powdered Drink Productions, In., Tom Lase, Telltale ‘lms, nc, Jettey F, January, January Lounge Productions, LLC, Matthew Goodwin, Monty ‘Simons, Montster Acton, In., Austin Amelio, and John Doe Corporations A throwgh Z, showing the Cours follows. 1. PARTIES, JURISDICTION, AND VENUE. 1 Plaintiff Susan Bemecker (*Plantfl) isa resident of Lo ana, the mother of Fohn Bemecker "John", deceased, and the Executx of John’s Estate, Plan brings this ation for tho wrongful dou of John and for the injuries he stained and pain and suffering he endure prior to his death, Plaintiff submits to the jurisdiction and venue ofthis Court 2. John served as a stunt double performer on Episode 807 ofthe television series The Walking Dead. Season 8 of The Walking Dead, of which Episode 807 was a pat was med primarily in Georgia, including inthe City of Seno, Coweta County. 3. John’s services as a stunt double performer were provided to Defendant Stalwart Films [LLC through his “oan-out” corporation, Prodigy Stunts, LLC “Prodigy Stunts”) A “loan-out” corporation is a company formed as a separate lepal entity that enters ito contracts with producers, production companies eo “loan” or fumish the services ofthe producer, directo, ‘te, actor, or artist hat employ. 4 Defendant Stalwart Films, LLC (“Stalwart Films") isa Delaware corporation with a rincipal office aes ia California and registered to do business in Georgia. Stalwart Pils is «production services company that operates in Georgia and, a all times relevant tothe events sade the basis of tis Complaint, was involved inthe production of The Walking Dead, Stalwart Films may be served with process by delivering a summons snl copy ofthis Complaint ots registered agent for service of process, Cogency Global, In., 900 Old Roswell Lakes Parkway, Suite 310, Roswell, Fulton County, Georgi, 30076, Stalwart kms is sujet he rsction ofthis Court pursuant 9 OCGA, § 910591. s Defendant TWD Productions Vil, LLC (*TWD VIII, 8 Delaware compotion with ite pencipal of Now York and rogietored to do busineca in Georgia, TWD VII isa television production company that produces television programming throughout Georgia and, at all times relevant to the events made the bass ofthis Complaint, was responsible for the funding and production of Season 8 of The Walking Dead. TWD VIII may be served with process by