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Complaint With Exhibits (FINAL)

Complaint With Exhibits (FINAL)

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Published by: Deadspin on May 23, 2012
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1
Keith
A.
Fink,
Bar
No.
146841
Olaf
J.
Muller,
Bar
No.
247372
2
FINK
&
STEINBERGAttorneys
atLaw
3
11500
OlympicBoulevard,
Suite
316Los
Angeles,California
90064
4
Telephone:
(310)268-0780
5
Attorneys
for
Plaintiff
REEVES
NELSON
6
7
8
SUPERIORCOURT
OF
THE
STATE
OFCALIFORNIA
9
COUNTYOFLOS
ANGELES
-
CENTRALDISTRICT
10
REEVES
NELSON,
an
individual,
)
CASE
NO.
)
11
Plaintiff,
)
PLAINTIFFSCOMPLAINT
FOR:
)
12
v.
)
1.
DEFAMATION;
)
2.
FALSE
LIGHT;
13
TIME,
INC.,
a
Delawarecorporation;
)
3.
INTENTIONALINFLICTION
OFGEORGEDOHRMANN,
an
individual;
and
)
EMOTIONAL
DISTRESS;
14
DOES
1
to
50,
inclusive,
)
)
15
Defendants.
)
)
[JURY
TRIAL
DEMANDED]16
)
)
17
)
)
18
19
COMES
NOW
PLAINTIFF
REEVESNELSON
(“Nelsonand/or
Plaintiff’)
and
hereby
alleges
20
as
follows:
21
VENUE
AND
PARTIES
22
1.
PLAINTIFF
REEVESNELSON
is
and
all
times
relevant
heretowas
an
individual
23
residing
in
and/ordoing
substantialbusiness
in
theCounty
of
Los
Angeles,
State
of
California.
24
2.
DEFENDANT
TIME,
INC.
(“Time
and/or
“Defendant)
is
and
at
all
timesrelevant
25
heretowas
a
Delawarecorporationdoingsubstantialbusiness
inthe
County
of
Los
Angeles,
State
of
26
California.
Plaintiff
is
informed
and
believesthatTime
is
and
atall
times
relevant
hereto
was
the
27owner
and
publisher
of
the
international
sports
magazineweekly
SPORTS
ILLUSTRATED
(“Sports
2
8
Illustrated).
1
PLAINTIFFNELSON’SCOMPLAINT
FORDAMAGES
 
1
3.
DEFENDANTGEORGEDOHRMANN
(“Dohrmannand/or
“Defendant)
is
and
at
all
2
timesrelevant
heretowas
an
individual
doingsubstantial
business
in
theCounty
of
Los
Angeles,
State
3
of
California.
4
4.
Plaintiff
is
unaware
of
the
true
names
and
capacities,
whether
individual,
corporate,
5
associate
or
otherwise,
of
Defendant
DOES
1
to50,
inclusive,
and
therefore
sues
said
Defendants
by
6
suchfictitious
names.
Plaintiff
will
seek
leave
of
Court
to
amendthis
complaint
to
showthe
true
7
names
and
capacities
of
such
defendantswhen
the
same
havebeen
ascertained.
Plaintiff
is
informed,
8
believes
and
thereupon
alleges
that
each
of
the
fictitiouslynamed
defendants
is
responsible
to
Plaintiff
9
forthe
wrongful
acts,
injuriesand
damagessuffered
and
alleged
herein,
orare
subject
to
the
10
jurisdiction
of
the
Court
as
a
necessary
party
for
the
relief
herein
requested.
11
5.
Plaintiff
is
informed,believes
and
thereupon
alleges
that
each
of
theaforementioned
12
Defendants
(“Defendants”),
are
now
and
were
at
all
times
mentioned
hereinthe
agent,
principal,
13
partner,
joint
venturer,
employee,
subsidiary
entity,
parent
entity,
and/or
alter-ego
of
theremaining
14
Defendants,
and
that
all
of
the
actsand
conduct
alleged
hereinwereperformedwithin
thecourseand
15
scope
andin
the
furtherance
of
such
agency,
partnership,
joint
venture,
employment,
subsidiary,
parent,
16
and/or
alter-ego
relationship.
17
6.
Plaintiff
is
informed,believes
and
thereupon
alleges
that
each
of
theDefendantsknew
18
orshould
have
known
that
thewrongshereinmentioned
wereabout
to
be
committed
or
were
being
19
committed,
and
further
had
the
power
to
prevent
oraid
in
preventing
the
commission
of
thesame,
or
to
20
prevent
future
injurytherefrom.Defendants
refusedand/orfailed
to
prevent
or
aid
in
preventingthe
21
commission
of
said
wrongsor
injuries,
and
said
wrongs
wereinfact
committed
andinjuriesoccurred.
22
7.
Venue
is
properly
had
in
this
Court
in
that
all
or
substantially
all
of
the
events
and
23
occurrencesthat
are
the
basis
of
all
causes
of
action
set
forth
below
occurred
in
theCounty
of
Los
24Angeles,
State
of
California.
25
GENERALALLEGATIONS
26
8.
Plaintiff
Reeves
Nelson
is
a
formerstudent
and
college
basketballplayer
for
U.C.L.A.
27
He
is
presentlytwenty
years
old.
Prior
to
playing
for
U.C.L.A.,
Plaintiff
Nelson
was
a
starathlete
in
28high
school,earning
numerousaccolades
forhis
performance
on
both
the
basketball
andfootballteams.
2
PLAINTIFF
NELSON’SCOMPLAINTFOR
DAMAGES
 
1
Among
other
things,Nelson
was
named
to
the
first-team
All-Trans
Valley
League
three
timesand
twice
2
earned
All-State
awardsdu ring
his
latter
twoyears
of
high
school.
ESPN,
Rivals.com,
and
Scout.com
3
repeatedlyrated
him
among
thetop
high
school
basketball
players
in
the
country,and
Plaintiff
was
even
4
named
to
the
youth
divisions
of
the
U.S.A.
Olympic
team
in
2007and2008.
Nelson
playedfor
the
5
U.C.L.A.
basketballteam
from
2009
through
2011,
rapidly
earning
a
reputation
for
himself
as
one
of
6
the
teams
(and
collegeba sketball’s)rising
stars.
During
his
freshman
year,
Nelson
wasnamed
to
the
7
Pacific-lO
Conference’s
All
Freshman
Team.
He
also
earnedU.C.L.A.’s
Seymour
ArmondMemorial
8
Award/MostValuable
Freshmanalong
withteammate
and
future
N.B.A.
playerTyler
Honeycutt.
9
During
his
sophomore
year,
Nelson
was
twicenamed
the
Pacific-lOConferencePlayer
of
the
Week
and
10
repeatedly
led
histeam
in
scoring,
rebounding,
and
field
goal
percentage.
Following
the
2010-2011
11
season,
Nelsonwasnamed
to
the
All
Pacific-12Conference
Men’sFirst
Basketball
Team,
theU.S.
12BasketballWriters
AssociationDistrict
IX
Team,
and
the
NationalAssociation
of
BasketballCoaches
13All-District
20
Second
Team.
Healso
receivedU.C.L.A.’s
Gerald
A.
Finerman
Award
as
Team
14
ReboundingLeader
and
theCoach
John
WoodenAward/Tri-MostValuable
Player,
whichlatter
honor
15
heshared
withteammates
TylerHoneycutt
and
Malcolm
Lee.
16
9.
Because
of
his
outstandingperformance
during
his
first
two
seasons
at
U.C.L.A.,the
Los17
AngelesTimes
referenced
Nelson
in
December
2011as
amajorreason
why
UCLA
(2-5)
was
the
18
preseasonpick
to
win
thePac-12
Conference.”Unfortunately
for
Nelson,however,
hiscollege
19
basketball
career
at
U.C.L.A.was
abruptly
cut
shortwhen
hewas
suspended
and
shortly
thereafter
20
dismissed
from
U.C.L.A.’steam
in
early
December
2011.
21
10.
In
November
2011,
Nelson
was
suspendedbriefly
after
showing
uplate
to
a
team
22meeting
and
then
missing
a
teamflight
to
Hawaii
for
a
team
game.Onor
around
December
3,
2011,
23
during
a
teamgameagainst
the
University
of
Texas
at
Austin,Nelsonmissed
a
defensive
assignment
24
and
subsequentlylaughed
and
pointed
at
fans
chanting
his
name
late
inthe
game,
which
U.C.L.A.
25
ultimately
lost.
Forhisinsubordinate
conduct,
Nelson
was
dismissed
fromthe
teamby
Coach
26
Howland.His
mother
SheilaNelson
was
subsequently
quotedby
the
Los
Angeles
Times
onor
around
27December
9,
2011,
regarding
herson’s
behavior
and
his
dismissal
from
the
team.
Notwithstanding
his
28suspension
and
dismissalfro m
the
team,
Plaintiff
Nelson
still
enjoyed
a
good
reputation
as
an
honest,
3
PLAINTIFF
NELSON’SCOMPLAINTFOR
DAMAGES

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