(rage 1 of 32) 1 A. Douglas Mastroianni (150438) 2|| doug@admlaw.co FILED is 3 | £09 Rolling Hills Way of Las Angeles, Suite 200 4 Rolling Hills Estates, CA 90274 twa 28 2018 (213) 915-7316 xsl OerClerk Ss .» Deputy ‘ Mowe Soto | Atomeys for Plaintiff Jane Doe & 5 SUPERIOR COURT OF CALIFORNIA 10 COUNTY OF LOS ANGELES u 12 a 13| “TANEDOE,” CaseNo. BC699288 14 Plaintiff, vs. COMPLAINT FO! 15] RUSSELL W. SIMMONS and DOES 1- | 1. FORCIBLE RAPE; 50, inclusive, 2, INTENTIONAL INFLICTION 17 Defendants. OF EMOTIONAL DISTRESS; 3, NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS. 2B 4 28 26 COMPLAINT FOR RAPE 27 a 28 Aeay aes 08 Doo 1 Fageb 4 = Doo 3D = 1722545466 - Doo type = onma|Gage 2 of 32) 9Cs.09 7/05 1 2019 TRIAL: 097-237 2010 0SC:'0 5) 221.2028 g 8888 " pase paz g8 g gs oot 4 Paget 2 = Dog ID = 1792545666 - Doc type = emma,(age 3 of 32) 1 PLAINTIFF ALLEGES AS FOLLOWS: 2 1. Plaintiff “Jane Doe” ("Plaintiff” or “Jane”) is a resident of the State of 3|| California. 4 2. Defendant Russell W. Simmons is the founder of Def Jam Recordings. 5 | Def Jam was one of the most successful music labels of all time, releasing music 6||by LL Cool Jay, Run DMC, Beastie Boys, Public Enemy, Jay Z, 50 Cent and Kayne 7|| West, among many others. 8 3. Simmons immense wealth and history of sexual assaults are relevant to g||the amount of punitive damages that must be assessed against Simmons for his 10||Sexual assault, Simmons was reportedly paid more than $10,000,000 for his stake 11|]in Def Jam when it was sold to a major label. Simmons was reportedly paid another 19|| Nine Figure amount when he sold his clothing line. a 4, Simmons is a dangerous sexual predator who has repeatedly raped and. 14| Sexually assaulted women over the decades. A partial list of women who have 15 | Sourageously revealed that they have been raped and sexually assaulted by one of the most powerful men in the music industry over the last several decades, include Sherri Hines (raped by Simmons in 1983), Lisa Kirk (sexually assaulted by Simmons in 1988), Toni Sallie (raped by Simmons in 1988 and sexually assaulted by Simmons the following year), Keri Khalighi (in 1991 Simmons forces her to perform oral sex on him when she was 17), Jenny Lumet (raped by Simmons in 1991), Tina B (raped by Simmons in 1991), Drew Dixon (raped by Simmons in 1995), Natashia Williams-Blach (attempted sexual assault in 1996), Jennifer Jarosik (raped by Simmons in 2016). 5. Since only a small percentage of victims of sexual assault disclose that they have been victimized, this list of women is likely only a very small portion of 26 COMPLAINT FOR RAPE oot 4 Baget 3 - Doc XD = 1732545466 - Dee "ype = OTHER(rage 4 of 12) 1 | those that have actually been raped and otherwise assaulted by Simmons. 6. In interviews, Simmons has “apologized” for his long history of rape and sexual assault, by characterizing his predations as mere “thoughtlessness” — a lack of candor and self-awareness which demonstrates a failure to acknowledge the utter inhumanity he has demonstrated toward women his entire adult life. 2 3 4 5 6 7. The true names and capacities, whether individual, corporate, 7|[associate, or otherwise of Defendants DOES 1-50, inclusive, are unknown to 8 [plaintiff who, therefore, sues the DOE defendants by fictitious names. Plaintiffis 9 | informed and believes and thereon alleges that each of the defendants designated as 0 @ DOE is legally responsible in some manner for the events and happenings herein 11 | eferred to and legally caused the injuries and damages to Plaintiff as alleged 12|/herein. a 8. Plaintiff will amend this complaint to insert the true names and 14||Sapacities of the DOE defendants when they become known. = 9. Atall times mentioned herein, defendants, and each of them, were the 16 |[agents, employees, principals, subsidiaries, co-conspirators, successors and/or predecessors of each of the other defendants and were at all times acting within the course and scope of said relationship, and each defendant was fully aware of the conduct of the remaining defendants, and all defendants authorized, ratified, and ; approved the acts of each other. eile : oe comm: 8 10. Venue is proper in this judicial district pursuant to California Code of 8 22! Civil Procedure section 395 since Defendant recently moved to Los Angeles 3 7 County from New Jersey and resides in Los Angeles, County. - 25 26 COMPLAINT FOR RAPE 27 ~ 28 oot 1 Page# & ~ Boe 1D = 2732548666 - Doo type = OMERGage 8 of 32) 1 GENERAL ALLEGATIONS: DEFENDANT RAPES PLAINTIFF 11. Jane attended a concert of a Rap and Hip-Hop artists associated with Defendant. She was chaperoning her son (who was in elementary school at the time and a fan of the Def Jam acts). During the concert, Simmons approached Jane and invited her and her son to come backstage and meet the artists. They did. Simmons then invited Jane to go to the “after party” at the (now closed) Clarion hotel where he was staying after dropping her son off at home with a babysitter. They socialized at the hotel bar until Simmons asked Jane to show him local clubs. ‘They went to the CoCo Palms nightclub and then returned to the hotel with the intention of continuing to socialize at the bar. Simmons said he had to get 10 in ta | Something from his room and asked Jane to accompany him. She was reluctant, but {| Simmons insisted it was not an invitation to have sexual relations since he was 14] Sating a well-known model. 15 12. Assured by Simmons’ lies, Jane accompanied Simmons to his room. 16|) After entering the room, Simmons shut the door and said “Iam going tof__k 17}] you.” Plaintiff said she had no intention of having sexual relations with Simmons - 18|| - buthe replied “I am going tof___k you or I'm going to f___k your son. You let alone threaten to 19|| decide.” Jane was shocked that Simmons would threaten her 20|| rape her young son. Simmons threw her on the bed and raped her. There is at least 21] one witness who saw Jane leaving the hotel room in tears and Jane told several © 20}| people about the rape at or near the time of the assault. Therefore, there is 23] substantial independent corroboration of the horrific event. no 25 26 COMPLAINT FOR RAPE 27 ae +28 seen aneage 6 of 32) 1 FIRST CAUSE OF ACTION (Forcible Rape against Simmons and DOES 1-25) 13, Plaintiff realleges as if fully set forth herein paragraphs 1- 13 above. 14, Simmons raped Jane Doe. 15. Jane Doe did not consent to any sexual contact with Simmons. In fact, 2 3 4 Ss 6|| Simmons lied to plaintiff shortly before raping her in order to persuade Jane Doe to 7||accompany him to his hotel room where the rape occurred. 3 16. Asa result of the rape, plaintiff has suffered special and general 9 | damages in an amount to be proven at trial. ia 17. Simmons’ conduct was malicious and oppressive justifying an award 11 of punitive damages pursuant to California Civil Code section 3294. Given 12 Simmons wealth and history of rape and sexual misconduct, punitive damages of at 13 {least $10,000,000 are requested since any lesser amount will be insufficient to 14 [Punish the defendant and deter his future sexual misconduct. 1s SECOND CAUSE OF ACTION 16 (Intentional Infliction of Emotional Distress and DOES 1-25) "7 18. Plaintiff realleges as if fully set forth herein paragraphs 1- 15 1 above. 9 19. Simmons conduct was outrageous. - 20. Simmons conduct was intended to cause Jane Doe emotional distress. el 21. Jane Doe suffered severe emotional distress and Simmons conduct 2 | ** substantial factor in causing the emotional distress. oo 22. Simmons’ conduct was malicious and oppressive justifying an award. 4] unitive damages pursuant to California Civil Code section 3294. Given Me fa Simmons wealth and history of rape and sexual misconduct, punitive damages of at 26 ‘COMPLAINT FOR RAPE 27 - 28 oot 4 Pagel 6 ~ Doc XD = 1732545466 - Dee type = oR(rage 7 of 12) eo least $10,000,000 are requested since any lesser amount will be insufficient to punish the defendant and deter his future sexual misconduct. THIRD CAUSE OF ACTION (Negligent Infliction of Emotional Distress and DOES 1-25) 23. Plaintiff realleges as if fully set forth herein paragraphs 1- 20 above. 24, Simmons conduct was negligent. 25. Simmons conduct caused Jane Doe emotional distress. 26. Jane Doe suffered severe emotional distress and Simmons conduct ‘was substantial factor in causing the emotional distress. PRAYER FOR RELIEF: 1. General, special and punitive damages in an amount to be proven at trial but of at least $10,000,000; 2. Costs of suit; 3. Such other relief as the court deems appropriate. Dated: March 22, 2018 MASTROIANNI ~ FIRM For Plaintiff Jane Doe ‘COMPLAINT FOR RAPE 6- ‘boot 3 Faget 7 ~ Doo X0 = 1732545466 - Doc type = OTReage 8 of 12) GM-010 —-.M == os Gitte Wan cue Aotng ste GA S021 FILED ‘recerone no; (213) 915-7316. PAKNOS ‘Superior Court of California _arronvey Fon pumas. Plaintiff ‘County of Los Angeles [SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles resooese 111 North Hill Stee, e MAR 28 2018 ery ANO Ze CODE: Los Angeles, CA 90012 ‘Sherri R. Carter, Ex: OfficeriCter’ a : one Mas Bel DOE y. Simmons CIVIL CASE COVER SHEET Complex Case Designation ae * vain “Ch umiet | coiaee Cl vine | 00608288 | demanded demanded is Filed with first appearance by defendant | “Y°S* treneisins. 00) $es00ortes| "(Car usec Say | con Tava 7 i etn! ee ara ge Fh ane oxi re cas Was tt ba somite he oe ton Senet Prva Compe cv ueten ‘ato (2) [ET ereechocontacswaranty (06) (Cal: Rules of Cour, ules 3400-2403) [Uninsured motorist (46) {Rie 3.740 collections (08), [2 Antiruss trade coguiation (03) {21 otnercotecions (09) ‘Construction defect (10) verano i) vee) ‘Other contact (37) 1) secures migation (25) Tein pet rorat & Envronmenta/Toxc tort (30) Hows Crna ona reratz crag ca wa ua be Elesssoocl comets epomen sper Non-PUPOIWD (Other) Tort 2) wrrongtt eviction (33) types (4 (7 pusiessortwfar business precise (or) C= Othe rel property 26) tater Cl) cmamae Unit Detainee Or exercament of gman 20) & etamaton 3) (2M commercat (ot) ‘\ ntscetaneous civ Complaint TE rraws 6) ES) reosicentat 32 recon () tmtezectust property (19) 1 brgs 38) ) otter complaint (not specified above) (42) 1) Protessionat negligence (25) utictat Review Miscellaneous Civil Petition ( otterren upon wont (5) Te eset (5) Patra nd corport govemance (21) omer, peste sort) mame ce tegtomten 6) E smrwere ar ee [7 other employment (15) 1) other judicial review (39) 2 Thisease [Tis LeTisnot ~ complex under rule 8.400 ofthe California Rules of Court. the case is complex, mark the factors requling exceptional judicial management 2.1 Large number of separately represented parties. (_] Large number of witnesses b.[[) Extensive motion practice raising ditfcut or novel e.[_] Coordination with related actions pending in one or more cours ‘sus that wil bo time-consuming to resolve In olher counties, states, o counties, ona federal court (2) Substantial amount of documentary evidence +. [1] Substantial postjudgment judicial supervision ‘3. Remedies sought (oheck al that appt): a] monetary b.{—] normonetary; declaratory of nunctive 44 Number of eases of action (spect (1) Rape; (2) HED; @) NIED sriscase CJ's L]ienot a dlass acton si Cai thore are any knoan rid cases, le ad seve anatce fread cat. (You Date: March 22, 2018 AsDouglas Mastroianni » oe TY ESATO ORATORY NOTICE ‘Ent must ie ths cover sheet wth the fst papr fied in the action o proceeding (except smal claims cases or cases fed "Taunder the Probate Code, Famly Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220, Fallure to fle may result in sanctions + Fie this cover shootin ation to any cover sheet required by local court ul * Mthis case s compex under rule 3.400 et seq, ofthe Calfoma Rules of Cour, you must serve a copy ofthis cover sheet on all ‘ther pares tothe action or proceeding * Unless this is a collections case under rule 3.740 ora complex case, tis cover sheet wil be used for statistic! purposes on} ‘ee CIVIL CASE COVER SHEET aa Snes an ‘recast oot 1 Paget @ = Doc XD ~ 1732545466 - Doo Bype = omarage 9 of 12) mA ‘DOE v, Simmons 86699288 CIVIL CASE COVER SHEET ADDENDUM AND ‘STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) Ths form required pursuant to Local Rule 23 ial new cave ings inthe Loe Angeles Superior Cour ‘Step 1: After completing the Civil Case Cover Sheet (Judicial Council form CM-010), find the exact case type in Column A that cortesponds to the case type indicated in the Chl Case Cover Sheet. ‘Step 2: In Column 8, check the box for the type of action that best describes the nature of the case. Step 3: n column circle the number which explains the reason forthe court fling location you have chosen ‘Applicable Reasons for Choosing Court Fling Location (Column) +. are mabe fein San Woo Ceurhase, Cnt. 7. Lacon ae peter ales 2 Pemisve inn ceva ont € Lean tr ledorespnte ctor way, 2 tssoneerecne faction os 2. Lecalon wero ermare othe Fe ee, ‘tty prorat ry tn Nt Ose 10 Locln of ter Contant Oc. 1. Mando fn leon cose -unou dead DR eee eee romealecton limited collection, or personal injury). 6. Aco tsp peared ei. 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As100 Otner Cha Pettan 20 ‘Dew 19 eva) CIVIL CASE COVER SHEET ADDENDUM oeal Rle 23 {ASC Approved 03.04 AND STATEMENT OF LOCATION Page Sota Doct 1 Paged 11 ~ Doo 2D = 2732545466 - Boo type =(age 22 of 12) gee oe SORT Oy gmmone errr ‘Step 4: Statement of Reason and Address: Check the appropriate boxes for the numbers shown under Column C for the type of action that you have selected. Enter the address which isthe bass forthe filing location, including zip code. (No address required for class action cases) REASON: 1211 Laurel Way 01.02,03.04.05.06.07. 080 9.010.811. Beverly Hils ca | 90201 ‘Step 5: Certification of Assignment: | certify that this case i properly filed in the Central District of the Superior Court of California, County of Los Angeles {Code Civ. Proc., §392 et seq,, and Local Rule 2.3(@)(a)(E). PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY ‘COMMENCE YOUR NEW COURT CASE: 41. Original Complaint or Petition It fling @ Complaint, a completed Summons form for issuance by the Clerk, Civil Case Cover Sheet, Judicial Council form CM-010. it Case Cover Sheet Aedendum and Statement of Location form, LAGIV 108, LASC Approved 03-04 (Rev Payment in full ofthe fling fee, unless there is court order for waiver, partial or scheduled payments ‘8. Asigned order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plain or pettioneris 2 ‘minor under 18 years of age will be required by Cour in order to Issue @ summons, 7. Additonal copies of documents to be conformed by the Clerk. Copies ofthe cover sheet and this addendum ‘must be served along with the summons and complaint, or other inating pleading inthe case. & 2 ‘e ‘ACV 109 Reve) CIVIL CASE COVER SHEET ADDENDUM ‘ocal Rule 23 ASC Approves 2-04 AND STATEMENT OF LOCATION Page 4 of 4 ‘boob 1 Faget 12 - Doo 1D = 1732545466 - doc Type = OnIER