Jane Doe Complaint

1 JOHN C. MANLY, Esq. (State Bar No.
149080)
VINCE W. FINALDI (State Bar No. 238279)
2 ALEX CUNNY (State Bar No. 291567)
MANLY, STEWART & FINALDI
3 19100 Von Karman Ave., Suite 800
Irvine, CA 92612
4 Telephone: (949) 252-9990
Fax: (949) 252-9991
5
Attorneys for Plaintiff, JANE AA DOE
6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
9
10 JANE AA DOE, an individual, Case No.: _________________________
11 Plaintiff, COMPLAINT FOR DAMAGES FOR:
12 vs. (1) INTENTIONAL INFLICTIONOF

EMOTIONAL DISTRESS;
19100 Von Karman Avenue, Suite 800
(2) NEGLIGENCE;
13 DOE 1, a California corporation; DOE 2, a

California corporation; and DOES 3-50, (3) NEGLIGENT SUPERVISION;
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 inclusive, (4) NEGLIGENT RETENTION/HIRING;

Irvine, CA 92612
(5) NEGLIGENT FAILURE TO WARN,

15 Defendants. TRAIN OR EDUCATE; and
(6) BREACH OF FIDUCIARY DUTY.
16
[Filed Concurrently with Certificates of
17 Merit, Pursuant to C.C.P. § 340.1]
18 DEMAND FOR JURY TRIAL
19
20
21 COMES NOW, Plaintiff JANE AA DOE (“Plaintiff”), who hereby complains and alleges
22 against Defendants DOE 1, DOE 2, and DOES 3 through 50, inclusive (“Defendants”), as
23 follows:
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COMPLAINT FOR DAMAGES

1 PARTIES
2 1. At all times mentioned herein, Plaintiff JANE AA DOE (“Plaintiff”) was a
3 resident of the State of California. The name utilized by JANE AA DOE in this Complaint is not
4 the real name of JANE AA DOE, but is a fictitious name utilized to protect her privacy as a
5 victim of childhood sexual harassment, molestation and abuse. Plaintiff was born on February 21,
6 1974, was a minor throughout the period of childhood sexual abuse alleged herein, and lived with
7 her parents in Southern California. She brings this action pursuant to C.C.P. section 340.1 for the
8 childhood sexual abuse she suffered at the hands of MICHAEL JOSEPH JACKSON, DOE 1,
9 DOE 2, and DOES 3-50.
10 2. MICHAEL JOSEPH JACKSON (hereinafter “MICHAEL JACKSON”) was one
11 of the most famous and successful entertainers in pop music history. Plaintiff is informed,
12 believes, and thereupon alleges that, at all times relevant herein, MICHAEL JACKSON was a
13 resident of the State of California, County of Los Angeles. Plaintiff is further informed and
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 believes, and thereupon alleges, that MICHAEL JACKSON died in Los Angeles, California on
Irvine, CA 92612
15 June 25, 2009, at the age of fifty (50).

16 3. Plaintiff is informed and believes, and thereupon alleges, that Defendant DOE 1
17 (“DOE 1”) is a California corporation, with a principal place of business located in the County of
18 Los Angeles, State of California. Plaintiff is further informed and believes, and thereupon alleges,
19 that at all times relevant herein, DOE 1 was an entertainment company established by MICHAEL
20 JACKSON as his primary business entity and the entity that held most or all of the copyrights to
21 MICHAEL JACKSON’s music and videos. Plaintiff is further informed and believes, and
22 thereon alleges, that MICHAEL JACKSON was the president/owner and a representative/agent
23 of DOE 1 at all times relevant herein, and that in that capacity, DOE 1 had the ability to exercise
24 control over MICHAEL JACKSON’s business and personal affairs. Plaintiff is further informed
25 and believes, and thereon alleges, that MICHAEL JACKSON, with DOE 1’ full knowledge,
26 consent, and assistance, exploited this relationship with DOE 1 to gain access to Plaintiff, and to
27 set up, facilitate and arrange meetings and encounters between MICHAEL JACKSON and the
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1
1 minor Plaintiff and other children for the purpose of MICHAEL JACKSON’s engaging in
2 childhood sexual abuse of Plaintiff and others.
3 4. Plaintiff is informed and believes, and thereupon alleges, that Defendant DOE 2
4 (“DOE 2”) is a California corporation, with a principal place of business located in the County of
5 Los Angeles, State of California. Plaintiff is further informed and believes, and thereupon alleges,
6 that at all times relevant herein, DOE 2 was an entertainment company established by MICHAEL
7 JACKSON in part for the purpose of employing Plaintiff to work with MICHAEL JACKSON on
8 various projects, and further, that MICHAEL JACKSON was the president/owner and a
9 representative/agent of DOE 2 at all times relevant herein, and that in that capacity, DOE 2 had
10 the ability to exercise control over MICHAEL JACKSON’s personal and business affairs.
11 Plaintiff is further informed and believes, and thereon alleges, that MICHAEL JACKSON, with
12 DOE 2’s full knowledge, consent, and assistance, exploited this relationship to gain access to
13 Plaintiff, and to set up, facilitate, and arrange meetings and encounters between MICHAEL
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 JACKSON and the minor Plaintiff and other children for the purpose of MICHAEL JACKSON
Irvine, CA 92612
15 engaging in childhood sexual abuse of Plaintiff and others.

16 5. In performing the acts complained of herein, MICHAEL JACKSON acted with the
17 full knowledge, consent and cooperation of DOE 1 and DOE 2, who were his co-conspirators,
18 collaborators, facilitators and alter egos for the childhood sexual abuse alleged herein. DOE 1 and
19 DOE 2 were held out to the public to be businesses dedicated to creating and distributing
20 multimedia entertainment by MICHAEL JACKSON, however, in fact, they actually served dual
21 purposes. The thinly-veiled, covert second purpose of these businesses was to operate as a child
22 sexual abuse operation, specifically designed to locate, attract, lure and seduce child sexual abuse
23 victims. In fact, under this dual purpose, MICHAEL JACKSON and select few managing
24 agents/employees of DOE 1’s and DOE 2’s inner circle designed, developed and operated what is
25 likely the most sophisticated public child sexual abuse procurement and facilitation organization
26 the world has known. As a result thereof, Defendants DOE 1 and DOE 2 are liable for MICHAEL
27 JACKSON’s acts of childhood sexual abuse within the meaning of CCP §§340.1(a)(2) and (3),
28 and 340.1 (b)(2), in that said entities owed a duty of care to the Plaintiff, and their wrongful,
2
1 intentional and/or negligent acts, as well as knowing failure to take reasonable steps and
2 implement reasonable safeguards to avoid acts of unlawful sexual conduct by MICHAEL
3 JACKSON, were a legal cause of the childhood sexual abuse which resulted in injury to Plaintiff
4 as alleged herein.
5 6. Plaintiff is informed and believes, and thereupon alleges, that the true names and
6 capacities, whether individual, corporate, associate or otherwise, of Defendants named herein as
7 DOEs 3 through 50, inclusive, are unknown to Plaintiff, who therefore sues said Defendants by
8 such fictitious names. Plaintiff will amend Complaint to allege their true names and capacities
9 when such have been ascertained. Upon information and belief, each of the said DOE Defendants
10 is responsible in some manner under C.C.P. §§340.1(a)(1), (2) and (3), and 340.1 (b)(2) for the
11 occurrences herein alleged, and were a legal cause of the childhood sexual abuse which resulted
12 in injury to the Plaintiff as alleged herein.
13 7. Plaintiff is informed and believes, and on that basis alleges, that at all times
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 mentioned herein, there existed a unity of interest and ownership among Defendants and each of
Irvine, CA 92612
15 them, such that any individuality and separateness between Defendants, and each of them, ceased
16 to exist. Defendants and each of them, were the successors-in-interest and/or alter egos of the
17 other Defendants, and each of them, in that they purchased, controlled, dominated and operated
18 each other without any separate identity, observation of formalities, or other manner of division.
19 To continue maintaining the facade of a separate and individual existence between and among
20 Defendants, and each of them, would serve to perpetrate a fraud and an injustice.
21 8. At all times mentioned herein, MICHAEL JACKSON was an adult singer, dancer,
22 entertainer, teacher, mentor, and coach of both DOE 1 and DOE 2, acting as an employee,
23 managing agent, agent, officer, director and/or servant of such and/or was under their complete
24 control and/or supervision. MICHAEL JACKSON was hired by DOE 1 and DOE 2 to serve as a
25 singer, dancer, entertainer, teacher, mentor, and coach to, in part, mentor and train minors in the
26 entertainment industry. In so doing, DOE 1 and DOE 2 held MICHAEL JACKSON out to the
27 public, Plaintiff and Plaintiff’s family to be safe and of high ethical and moral repute, and to be in
28 good standing with the DOE 1 and DOE 2, the State of California, and the public in general. In
3
1 this capacity, MICHAEL JACKSON was placed into contact with, taught, mentored, coached,
2 and advised minors regarding the entertainment industry in general (including but not limited to
3 singing, dancing, performing, choreography, song writing), personal issues, academics, future
4 employment prospects, and general emotional and psychological issues. Both DOE 1 and DOE 2
5 held MICHAEL JACKSON out to the public, Plaintiff and Plaintiff’s parents to be a highly
6 qualified and safe entertainer, teacher, mentor, coach, and advisor who could and would assist
7 minors in the entertainment industry, and with working through personal and academic issues
8 they faced. Inherent in this representation was the understanding that MICHAEL JACKSON was
9 a person of high ethical and moral standing, selected to provide leadership, guidance, mentoring,
10 coaching, and advisement to minors, including Plaintiff. Plaintiff and her family reasonably
11 relied upon these representations and assumed that MICHAEL JACKSON was a person worthy
12 of their complete trust.
13 9. Plaintiff is informed and believes, and on that basis alleges, that at all times
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 mentioned herein, Defendants and each of them and MICHAEL JACKSON were the agents,
Irvine, CA 92612
15 representatives and/or employees of each and every other Defendant. In doing the things
16 hereinafter alleged, Defendants and each of them, and MICHAEL JACKSON, were acting within
17 the course and scope of said alternative personality, capacity, identity, agency, representation
18 and/or employment and were within the scope of their authority, whether actual or apparent.
19 Plaintiff is informed and believes, and on that basis alleges, that at all times mentioned herein,
20 Defendants and each of them and MICHAEL JACKSON were the trustees, partners, servants,
21 joint venturers, shareholders, contractors, and/or employees of each and every other Defendant,
22 and the acts and omissions herein alleged were done by them, acting individually, through such
23 capacity and within the scope of their authority, and with the permission and consent of each and
24 every other Defendant and that said conduct was thereafter ratified by each and every other
25 Defendant, and that each of them is jointly and severally liable to Plaintiff.
26 FACTUAL ALLEGATIONS
27 10. In approximately 1986, when Plaintiff was approximately 12 years of age, her
28 parents took her and her brothers on a trip to San Francisco. Plaintiff, admittedly, was a
4
1 “tomboy.” On the way back to Southern California, they stopped by the Hayvenhurst home of
2 MICHAEL JACKSON and location where he conducted business for DOES 1-2, to sightsee.
3 While at the front gates, MICHAEL JACKSON arrived driving his Mercedes motor vehicle. He
4 drove into the gate and signaled to his security guard to allow Plaintiff and her mother access to
5 the property, beyond the gates. Plaintiff and her mother obliged, and walked onto the residence
6 grounds, being escorted by the security guard. They spoke with MICHAEL JACKSON at his car
7 for several minutes. MICHAEL JACKSON then drove to the residence and entered. The security
8 guard escorted Plaintiff and her mother to MICHAEL JACKSON’s candy room in the residence.
9 MICHAEL JACKSON was peering at them through a window in the residence.
10 11. While on the property, MICHAEL JACKSON spoke with the security guard
11 through his walkie talkie and asked him to obtain Plaintiff’s telephone number. The security
12 guard then requested and received Plaintiff’s family’s home phone number. MICHAEL
13 JACKSON began calling Plaintiff’s home within the week, to speak with Plaintiff. They began
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 conversing over the telephone every day. MICHAEL JACKSON began inviting Plaintiff to spend
Irvine, CA 92612
15 time with him, groomed her for sexual abuse and began sexually abusing her.
16 12. The sexual abuse of Plaintiff by MICHAEL JACKSON began in approximately
17 1986, when she was 12 years old, and continued until just before she turned 15 years old, in 1989,
18 and was going through puberty.
19 13. The sexual abuse of Plaintiff by MICHAEL JACKSON included MICHAEL
20 JACKSON fondling Plaintiff sexually on her genitals and body, digitally penetrating Plaintiff,
21 giving Plaintiff what he termed “movie kisses” where he tongue kissed her mouth and body,
22 orally copulated Plaintiff, forced Plaintiff to orally copulate him, rubbed his clothed and
23 unclothed body against Plaintiff’s, and rubbed his penis on Plaintiff’s vagina and attempted to
24 fully insert it into her vagina, only partially inserting it and causing Plaintiff to bleed. These acts
25 by MICHAEL JACKSON, using his position of trust and authority over her, for his own sexual
26 gratification, upon Plaintiff without her consent as she was a minor and unable to give valid, legal
27 consent.
28
5
1 14. Before, during and after the sexual abuse period Plaintiff suffered, MICHAEL
2 JACKSON would buy Plaintiff gifts and send her notes and letters of affection. The letters stated
3 such things as: “I love you and miss you very much” and “I love you sooo much also you’r
4 making me love you even more the more I talk to you I’m crazy about you all my love Michael.”
5 True and correct copies of these two notes, which are amongst many given to Plaintiff by
6 MICHAEL JACKSON, DOE 1 and DOE 2, which Plaintiff still possesses, are attached here
7 collectively as Exhibit “A”. MICHAEL JACKSON would call Plaintiff’s family home very
8 frequently, requesting to speak with Plaintiff. He would then speak with Plaintiff for hours at a
9 time, about varying subjects, including his affection for Plaintiff. He would tell her things that
10 were to be kept “secret” from Plaintiff’s parents and everyone else. By giving Plaintiff a
11 nickname, giving her gifts, sending her notes and letters, speaking with her over the telephone for
12 long hours, and telling her “secrets” which were to be kept from her parents and others,
13 MICHAEL JACKSON was grooming Plaintiff for sexual abuse.

Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 15. MICHAEL JACKSON also groomed Plaintiff’s mother. He would spend extended
Irvine, CA 92612
15 periods of time on the phone with her, telling her intimate details about his life and his past, in an
16 attempt to gain a “closeness” with Plaintiff’s mother and earn her trust so that she would allow
17 him to spend time alone with Plaintiff. He would tell her about how much he cared for Plaintiff as
18 a friend. He also gave her gifts such as flowers, gift baskets, a television and an autographed
19 photograph of another celebrity.
20 16. Defendants DOE 1 and DOE 2 orchestrated, facilitated and enabled the sexual
21 abuse of Plaintiff by MICHAEL JACKSON by assisting in the grooming process (buying gifts
22 for Plaintiff, picking Plaintiff up and taking her to MICHAEL JACKSON to spend time with him,
23 driving Plaintiff home, sending letters and notes to Plaintiff, sending gifts to Plaintiff, setting up
24 meetings between Plaintiff and MICHAEL JACKSON, isolating Plaintiff with MICHAEL
25 JACKSON for extended periods of time, and booking and paying for accommodations for
26 MICHAEL JACKSON and Plaintiff).
27 17. The sexual abuse of Plaintiff by MICHAEL JACKSON occurred in various
28 locations throughout Los Angeles, including but not limited to MICHAEL JACKSON’s
6
1 Hayvenhurst home, where he lived and conducted business for and on behalf of DOES 1-2, at
2 Universal Studios while he was on the set for Moonwalker and working for DOES 1-2, at the
3 Universal Sheraton hotel while he was filming Moonwalker and working for DOES 1-2, at his
4 Neverland residence, where he lived and conducted business for and on behalf of DOES 1-2, on
5 the set of the Smooth Criminal video shoot which was being created for and on behalf of DOES
6 1-2, in the back of his limousine that he used to travel and conduct business for DOES 1-2, at the
7 Lorimar Studios in Studio City where he was conducting business for DOES 1-2, at his personal
8 residence apartment/condo he nicknamed the “Hideout” where he lived and conducted business
9 for DOES 1-2, all during times that he was working for and on behalf of DOE 1 and DOE 2.
10 During these times, MICHAEL JACKSON, DOE 1 and DOE 2 took physical custody and control
11 of the minor Plaintiff, entering into a special, trusting, confidential and in loco parentis
12 relationship with her, owing her a duty of care to protect her from reasonably foreseeable harm.
13 PENAL CODE AND CIVIL CODE VIOLATIONS

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ATTORNEYS AT LAW
14 18. As used in C.C.P. § 340.1, “childhood sexual abuse” includes “any act committed
Irvine, CA 92612
15 against the plaintiff that occurred when the plaintiff was under the age of 18 years and that would
16 have been proscribed by Section 266j of the California Penal Code (“Penal Code”); Section 285
17 of the Penal Code; paragraph (1) or (2) of subdivision (b), or of subdivision (c), of Section 286 of
18 the Penal Code; subdivision (a) or (b) of Section 288 of the Penal Code; paragraph (1) or (2) of
19 subdivision (b), or of subdivision (c), of Section 288a of the Penal Code; subdivision (h), (i), or
20 (j) of Section 289 of the Penal Code; Section 647.6 of the Penal Code….”
21 Penal Code § 266j
22 19. As set forth more fully above, on multiple occasions MICHAEL JACKSON and
23 DOES 1-2, inclusive, intentionally committed acts against Plaintiff that occurred when Plaintiff
24 was under the age of eighteen (18), and which would have been proscribed by Section 266j of the
25 Penal Code or any prior laws of California of similar effect at the time the acts were committed,
26 by intentionally giving, transporting, providing, or making available, or offering to give,
27 transport, provide, or make available to another person, Plaintiff ,who was a child under the age
28 of sixteen (16), for the purpose of any lewd or lascivious act as defined in Penal Code § 288, or
7
1 by causing, inducing, or persuading Plaintiff, a child under the age of sixteen (16), to engage in
2 such an act with another person.
3 Penal Code § 286(b)(1)
4 20. As set forth more fully above, MICHAEL JACKSON and DOES 1-2, inclusive,
5 intentionally committed an act against Plaintiff that occurred when Plaintiff was under the age of
6 eighteen (18), and which would have been proscribed by Section 286(b)(1) of the Penal Code or
7 any prior laws of California of similar effect at the time the act was committed, by participating in
8 an act of sodomy (sexual conduct consisting of contact between the penis of one person and the
9 anus of another person) with Plaintiff, who was under eighteen (18) years of age. Any sexual
10 penetration, however slight, is sufficient to complete the crime of sodomy.
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14 eighteen (18), and which would have been proscribed by Section 286(b)(2) of the Penal Code or
Irvine, CA 92612
15 any prior laws of California of similar effect at the time the act was committed, by participating in
17 anus of another person) with Plaintiff who was under sixteen (16) years of age when MICHAEL
18 JACKSON was over the age of twenty-one (21) years. Any sexual penetration, however slight, is
19 sufficient to complete the crime of sodomy.
20 Penal Code § 286(c)(2)(A)
23 eighteen (18), and which would have been proscribed by Section 286(c)(2)(A) of the Penal Code
24 or any prior laws of California of similar effect at the time the act was committed, by committing
26 anus of another person) when the act was accomplished against Plaintiff’s will by means of
27 duress. Any sexual penetration, however slight, is sufficient to complete the crime of sodomy.
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8
1 Penal Code § 286(c)(2)(C)
4 eighteen (18), and which would have been proscribed by Section 286(c)(2)(C) of the Penal Code
5 or any prior laws of California of similar effect at the time the act was committed, by committing
7 anus of another person) with Plaintiff who was a minor fourteen (14) years of age or older when
8 the act was accomplished against Plaintiff’s will by means of duress. Any sexual penetration,
9 however slight, is sufficient to complete the crime of sodomy.
10 Penal Code § 288(a)
11 24. On multiple occasions, as set forth more fully above, MICHAEL JACKSON and
13 was under the age of eighteen (18), and which would have been proscribed by Section 288(a) of
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14 the Penal Code or any prior laws of California of similar effect at the time the acts were
Irvine, CA 92612
15 committed, by willfully and lewdly committing any lewd or lascivious act, including any of the
16 acts constituting other crimes provided for in Part 1 of the Penal Code, upon or with the body, or
17 any part or member thereof, of Plaintiff who was under the age of fourteen (14) years, with the
18 intent of arousing, appealing to, or gratifying the lust, passions, or sexual desires of MICHAEL
19 JACKSON or Plaintiff.
23 was under the age of eighteen (18), and which would have been proscribed by Section 288(b)(1)
24 of the Penal Code or any prior laws of California of similar effect at the time the acts were
25 committed, by willfully and lewdly committing any lewd or lascivious act, including any of the
26 acts constituting other crimes provided for in Part 1 of the Penal Code, upon or with the body, or
27 any part or member thereof, of Plaintiff who was under the age of fourteen (14) years, with the
28
9
1 intent of arousing, appealing to, or gratifying the lust, passions, or sexual desires of MICHAEL
2 JACKSON or Plaintiff, by use of duress.
3 Penal Code § 288a(b)(1)
6 was under the age of eighteen (18), and which would have been proscribed by Section 288a(b)(1)
8 committed, by participating in an act of oral copulation (the act of copulating the mouth of one
9 person with the sexual organ or anus of another person) with Plaintiff who was under eighteen
10 (18) years of age.
11 Penal Code § 288a(b)(2)
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14 was under the age of eighteen (18), and which would have been proscribed by Section 288a(b)(2)
Irvine, CA 92612
17 person with the sexual organ or anus of another person) with Plaintiff who was under sixteen (16)
18 years of age and MICHAEL JACKSON was over the age of twenty-one (21).
19 Penal Code § 288a(c)(1)
22 was under the age of eighteen (18), and which would have been proscribed by Section 288a(c)(1)
25 person with the sexual organ or anus of another person) with Plaintiff who was under fourteen
26 (14) years of age and more than 10 years younger than MICHAEL JACKSON.
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10
1 Penal Code § 288a(c)(2)(A)
4 was under the age of eighteen (18), and which would have been proscribed by Section
5 288a(c)(2)(A) of the Penal Code or any prior laws of California of similar effect at the time the
6 acts were committed, by committing an act of oral copulation (the act of copulating the mouth of
7 one person with the sexual organ or anus of another person) when the act was accomplished
8 against Plaintiff’s will by means of duress.
9 Penal Code § 288a(c)(2)(B)
13 288a(c)(2)(B) of the Penal Code or any prior laws of California of similar effect at the time the
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Irvine, CA 92612
15 one person with the sexual organ or anus of another person) upon Plaintiff who was under
16 fourteen (14) years of age, when the act was accomplished against Plaintiff’s will by means of
17 duress.
18 Penal Code § 288a(c)(2)(C)
22 288a(c)(2)(C) of the Penal Code or any prior laws of California of similar effect at the time the
24 one person with the sexual organ or anus of another person) upon Plaintiff who was fourteen (14)
25 years of age or older, when the act was accomplished against Plaintiff’s will by means of duress.
26 Penal Code § 288a(c)(3)
11
1 was under the age of eighteen (18), and which would have been proscribed by Section 288a(c)(3)
3 committed, by committing an act of oral copulation (the act of copulating the mouth of one
4 person with the sexual organ or anus of another person) where the act was accomplished against
5 Plaintiff’s will by threatening to retaliate in the future against Plaintiff or any other person, and
6 there was a reasonable possibility that MICHAEL JACKSON would execute the threat.
7 Penal Code § 289(h)
8 33. On multiple occasions, MICHAEL JACKSON and DOES 1-2, inclusive,
9 intentionally committed acts against Plaintiff that occurred when Plaintiff was under the age of
10 eighteen (18), and which would have been proscribed by Section 289(h) of the Penal Code or any
11 prior laws of California of similar effect at the time the acts were committed, by participating in
12 an act of sexual penetration (the act of causing the penetration, however slight, of the genital or
13 anal opening of another person or causing another person to so penetrate the defendant’s or
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14 another person’s genital or anal opening for the purpose of sexual arousal, gratification, or abuse
Irvine, CA 92612
15 by any foreign object (including any part of the body except a sexual organ), substance,
16 instrument, or device) with Plaintiff who was under eighteen (18) years of age.
17 Penal Code § 289(i)
20 was under the age of eighteen (18), and which would have been proscribed by Section 289(i) of
22 committed by participating in an act of sexual penetration (the act of causing the penetration,
23 however slight, of the genital or anal opening of another person or causing another person to so
24 penetrate the defendant’s or another person’s genital or anal opening for the purpose of sexual
25 arousal, gratification, or abuse by any foreign object (including any part of the body except a
26 sexual organ), substance, instrument, or device) with Plaintiff who was under sixteen (16) years
27 of age and MICHAEL JACKSON was over the age of twenty-one (21) years.
28 ///
12
1 Penal Code § 289(j)
4 was under the age of eighteen (18), and which would have been proscribed by Section 289(j) of
6 committed by participating in an act of sexual penetration (the act of causing the penetration,
7 however slight, of the genital or anal opening of another person or causing another person to so
8 penetrate the defendant’s or another person’s genital or anal opening for the purpose of sexual
9 arousal, gratification, or abuse by any foreign object (including any part of the body except a
10 sexual organ), substance, instrument, or device) with Plaintiff who was under fourteen (14) years
11 of age and who was more than 10 years younger than MICHAEL JACKSON.
12 Penal Code § 647.6(a)(1)
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Irvine, CA 92612
15 was under the age of eighteen (18), and which would have been proscribed by Section 647.6(a)(1)
17 committed, by annoying or molesting Plaintiff when she was a child under eighteen (18) years of
18 age.
19 Civil Code § 1708.5
20 37. On multiple occasions, as set forth more fully above, MICHAEL JACKSON acted
21 with the intent to cause a harmful and offensive contact with Plaintiff’s intimate parts as set forth
22 in California Civil Code §1708.5 regarding sexual battery, and did, in fact, cause such sexually
23 harmful and offensive contact. On each occasion, Plaintiff did not consent to MICHAEL
24 JACKSON’s conduct.
25 Civil Code § 1708.5
26 38. On multiple occasions, as set forth more fully above, MICHAEL JACKSON acted
27 with the intent to cause a harmful and offensive physical contact with Plaintiff by the use of his
28 intimate part as set forth in Civil Code Section 1708.5 regarding sexual battery, and did, in fact,
13
1 cause such sexually harmful or offensive contact. On each occasion, Plaintiff did not consent to
2 MICHAEL JACKSON’s conduct. The physical contact alleged above, offends one’s reasonable
3 sense of personal dignity.
4 39. MICHAEL JACKSON did sexually harass, molest and abuse Plaintiff, who was a
5 minor at the time. Such conduct was done for MICHAEL JACKSON’s sexual gratification,
6 while working as an agent, employee, officer and director of, and on behalf of, DOES 1-2, and
7 under their active control and supervision, and was performed on Plaintiff without his free
8 consent, as Plaintiff was a mere minor and thus unable to give valid, legal consent to such sexual
9 acts.
10 40. On June 25, 2009, MICHAEL JACKSON died.
11 DAMAGES
12 41. As a direct and proximate result of her sexual abuse by MICHAEL JACKSON and
13 DOES 1-2, Plaintiff has suffered, and will continue to suffer, psychological, mental and
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14 emotional distress, including but not limited to nightmares, stress, fear, shame, humiliation,
Irvine, CA 92612
15 depression, physical distress, anxiety, depression, sadness, anger, trust issues, and control issues.
16 She has and will continue to incur expenses for mental and medical care due to the abuse,
17 according to proof at trial.
18 42. As a direct and proximate result of her sexual abuse by MICHAEL JACKSON and
19 DOES 1-2, Plaintiff has been damaged in her employment, specifically losing wages and earnings
20 and economic benefits according to proof at the time of trial. Plaintiff has lost wages as a result of
21 the abuse she suffered at the hands of Defendants, and will continue to lose wages in an amount
22 to be determined at trial. Plaintiff has suffered economic injury, all to Plaintiff's general, special
23 and consequential damage in an amount to be proven at trial, but in no event less than the
24 minimum jurisdictional amount of this Court.
25 43. As is set forth herein, Defendants and each of them have failed to uphold
26 numerous mandatory duties imposed upon them by state and federal law, and by written policies
27 and procedures applicable to Defendants, including but not limited to the following:
28
14
1 * Duty to protect minor children in their care, and provide adequate
supervision;
2
* Duty to ensure that any direction given to employees is lawful, and that
3 adults act fairly, responsibly and respectfully towards other adults and
minor children;
4
* Duty to properly train teachers, mentors, coaches, and advisors so that they
5 are aware of their individual responsibility for creating and maintaining a
safe environment;
6
* Duty to supervise employees and minor children in its care, enforce rules
7 and regulations prescribed for childcare organizations, exercise reasonable
control over minor children in its care as is reasonably necessary to
8 maintain order, protect property, or protect the health and safety of
employees and minor children or to maintain proper and appropriate
9 conditions conducive to learning and child development;
10 * Duty to exercise careful supervision of the moral conditions in the youth
programs set forth by Defendants DOE 1 and DOE 2;
11
* Duty to properly monitor minor children, prevent or correct harmful
12 situations or call for help when a situation is beyond their control;
13 * Duty to ensure that personnel are actually on hand and supervising

Telephone: (949) 252-9990
students;
ATTORNEYS AT LAW
14
Irvine, CA 92612
* Duty to provide enough supervision to minor children, including the

15 Plaintiff;
16 * Duty to supervise diligently;
17 * Duty to act promptly and diligently and not ignore or minimize problems;
18 * Duty to refrain from violating Plaintiff's right to protection from bodily
restraint or harm, from personal insult, from defamation, and from injury to
19 her personal relations (Civil Code § 43);
20 * Duty to abstain from injuring the person or property of Plaintiff, or
infringing upon any of her rights (Civil Code § 1708); and
21
* Duty to report suspected incidents of child abuse and more specifically
22 childhood sexual abuse (Penal Code §§ 11166, 11167).
23
44. The conduct alleged above included intentional, outrageous, malicious, despicable
24
and oppressive acts beyond the bounds of decent behavior, which were undertaken, wantonly,
25
oppressively and with a conscious disregard for Plaintiff’s rights as a child. Plaintiff is therefore
26
entitled to an award of punitive damages in an amount sufficient to punish, deter and make an
27
example of those Defendants engaging in such behavior according to proof at trial. In subjecting
28
15
1 Plaintiff to the wrongful treatment herein described, Defendants DOES 1-2 and MICHAEL
2 JACKSON acted willfully and maliciously with the intent to harm Plaintiff, and in conscious
3 disregard of Plaintiff's rights, so as to constitute malice and/or oppression under California Civil
4 Code section 3294. Plaintiff is informed, and on that basis alleges, that these willful, malicious,
5 and/or oppressive acts, as alleged herein above, were ratified by the officers, directors, and/or
6 managing agents of the Defendants DOES 1-2 and DOES 3 through 50, including MICHAEL
7 JACKSON. Plaintiff is therefore entitled to the recovery of punitive damages, in an amount to be
8 determined by the court, against Defendants DOES 1-2, and DOES 3 through 50, in a sum to be
9 shown according to proof.
10 ESTOPPEL
11 45. Before, during and after the sexual abuse of Plaintiff, MICHAEL JACKSON
12 threatened, intimidated and coerced the minor Plaintiff, who was under extreme duress due to his
13 actions, into not informing anyone of her sexual abuse or pursuing legal action therefor. These
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 threats included telling Plaintiff that she would be physically harmed if she ever told anyone, and
Irvine, CA 92612
15 that she would get in trouble with law enforcement and go to jail, forcing Plaintiff to promise not
16 to tell anyone. These threats, which Plaintiff wholeheartedly believed due to MICHAEL
17 JACKSON’s immense fame, fortune and notoriety, as well as the company he kept, including his
18 business manager FRANK DILEO, prevented Plaintiff from coming forward at an earlier time.
19 The coercive effects of these threats, duress, and intimidation did not cease until, after MICHAEL
20 JACKSON passed away, Plaintiff discovered others had filed actions against MICHAEL
21 JACKSON and DOES 1-2 for sexual assault, namely Wade Robson, and were not physically
22 injured for so doing.
23 NEXUS
24 46. In the beginning of September, 2016, Plaintiff, while reflecting on the child sexual
25 abuse she had suffered at the hands of MICHAEL JACKSON and DOES 1-2, for the first time in
26 her life, reasonably discovered that her psychological injuries or illnesses occurring after the age
27 of majority, as listed in paragraph 40 herein-above, were caused by the sexual abuse she suffered
28 at the hands of MICHAEL JACKSON and DOES 1-2. As a layperson with no specialized
16
1 training in psychology or the medical field, Plaintiff was blameless for not making this nexus at
2 an earlier date than she did, and had no way of making such nexus at an earlier time.
3 INSURANCE CODE § 11583
4 47. On March 19, 1990, when Plaintiff was a 16-year-old minor, MICHAEL
5 JACKSON, DOE 1 and DOE 2 paid Plaintiff the sum of $2,500.00, to compensate her for the
6 sexual abuse she had suffered at the hands of MICHAEL JACKSON. It was purposely falsely
7 labeled as a “gift” so as to conceal the true nature and source of the payment. Attached hereto as
8 Exhibit “B” is a true and correct copy of that check stub.
9 48. On December 18, 1991, when Plaintiff was a 17-year-old minor, MICHAEL
10 JACKSON, DOE 1 and DOE 2 paid Plaintiff the sum of $10,000.00, in cash, to compensate her
11 for the sexual abuse she had suffered at the hands of MICHAEL JACKSON. Attached hereto as
12 Exhibit “C” is a true and correct copy of the currency strap for that cash payment.
13 49. On January 13, 1992, when Plaintiff was a 17-year-old minor, MICHAEL
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 JACKSON, DOE 1 and DOE 2 paid Plaintiff the sum of $150,000.00, to compensate her for the
Irvine, CA 92612
15 sexual abuse she had suffered at the hands of MICHAEL JACKSON. The check was made out in
16 the name of Plaintiff’s friend at the time, who neither MICHAEL JACKSON, nor DOE 1, nor
17 DOE 2, had ever met or known or worked for/with, so as to conceal the true nature and source of
18 the payment. Attached hereto as Exhibit “D” is a true and correct copy of that check and
19 check stub.
20 50. On January 21, 1993, MICHAEL JACKSON, DOE 1 and DOE 2 paid Plaintiff the
21 sum of $130,000.00, to compensate her for the sexual abuse she had suffered at the hands of
22 MICHAEL JACKSON. Attached hereto as Exhibit “E” is a true and correct copy of that
23 check.
24 51. On December 23, 1993, MICHAEL JACKSON, DOE 1 and DOE 2 paid Plaintiff
25 the sum of $600,000.00, to compensate her for the sexual abuse she had suffered at the hands of
26 MICHAEL JACKSON. Attached hereto as Exhibit “F” is a true copy of that check.
27 52. On various dates between the inception of Plaintiff’s sexual abuse, in 1986, when
28 she was a minor, and December of 1993, MICHAEL JACKSON and DOES 1-2 gave Plaintiff
17
1 multiple cash payments intended to compensate her for the sexual abuse she had suffered at the
2 hands of MICHAEL JACKSON. Included was an October 11, 1993, payment of $10,000.00 “Per
3 Written Authorization” for “Entertainment.” Attached hereto as Exhibit “G” is a true and
4 correct copy of that cash withdrawal. In total, MICHAEL JACKSON and DOES 1-2 provided
5 Plaintiff in excess of $900,000.00 to compensate her for the child sexual abuse she suffered at the
6 hands of MICHAEL JACKSON.
7 53. At no time whatsoever during or at the beginning of the above-noted payments to
8 Plaintiff for the child sexual abuse suffered did MICHAEL JACKSON or DOES 1-2 inform
9 Plaintiff, in writing or otherwise, of the statute of limitations applicable to her claims for
10 childhood sexual abuse at the hands of MICHAEL JACKSON and DOES 1-2. To this date,
11 Plaintiff has never received such written notification from MICHAEL JACKSON or DOES 1-2.
12 54. Insurance Code section 11583 states that “[n]o advance payment or partial
13 payment of damages made by any person, or made by his insurer under liability insurance... as an
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 accommodation to an injured person or on his behalf to others... because of an injury or death

Irvine, CA 92612
15 claim or potential claim against any person or insured shall be construed as an admission of
16 liability by the person claimed against, or of that person’s or the insurer’s recognition of such
17 liability.” The Insurance Code further states, however, that “any person, including any insurer,
18 who makes such an advance or partial payment, shall at the time of beginning payment, notify the
19 recipient thereof in writing of the statute of limitations applicable to the cause of action which
20 such recipient may bring against such person as a result of such injury or death” and that a
21 “failure to provide such written notice shall operate to toll any such applicable statute of
22 limitations or time limitations from the time of such advance or partial payment until such written
23 notice is actually given. That notification shall not be required if the recipient is represented by an
24 attorney.”
25 55. Pursuant to Insurance Code section 11583, Plaintiff’s statute of limitations was
26 tolled from the inception of payments to Plaintiff for the childhood sexual abuse she suffered, in
27 1986, to the present. Because the statute of limitations applicable to Plaintiff’s child sexual abuse
28 claims against MICHAEL JACKSON and DOES 1-2 had not lapsed as of 1986, and have been
18
1 tolled since such time, Plaintiff’s claims herein have not lapsed due to any applicable statute of
2 limitations.
3 OTHER SEXUAL ABUSE ALLEGATIONS
4 56. On September 14, 1993, one of the many boys MICHAEL JACKSON sexually
5 abused, Jordan Chandler, brought a civil lawsuit against MICHAEL JACKSON, which resulted
6 in an investigation by the Los Angeles Police Department.
7 LIABILITY OF DEFENDANTS
8 57. As a minor guest of MICHAEL JACKSON and DOE 1 and DOE 2, where
9 MICHAEL JACKSON was employed and worked, Plaintiff was under MICHAEL JACKSON’s,
10 DOE 1, and DOE 2’ direct supervision, care and control, thus creating a special relationship,
11 fiduciary relationship, and/or special care relationship with Defendants, and each of them.
12 Additionally, as a minor child under the custody, care and control of Defendants, Defendants
13 stood in loco parentis with respect to Plaintiff while she was attending events and functions at
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 locations run and controlled by Defendants DOE 1 and DOE 2. As the responsible parties and/or
Irvine, CA 92612
15 employers controlling MICHAEL JACKSON, Defendants were also in a special relationship with
16 Plaintiff, and owed special duties to Plaintiff.
17 58. Plaintiff is informed and believes, and on that basis alleges, that Defendants knew
18 or had reason to know, or were otherwise on notice, that MICHAEL JACKSON had engaged in
19 unlawful sexually-related conduct with minors in the past, and/or was continuing to engage in
20 such conduct with Plaintiff, and failed to take reasonable steps, and to implement reasonable
21 safeguards, to avoid acts of unlawful sexual conduct in the future by MICHAEL JACKSON, such
22 as that which occurred with Plaintiff, including but not limited to preventing or avoiding
23 placement of MICHAEL JACKSON in a function or environment in which contact with children
24 was an inherent part of that function or environment. Defendants had a duty to disclose to these
25 facts to Plaintiff, his parents and others, but negligently and/or intentionally suppressed,
26 concealed or failed to disclose this information for the express purposes of facilitating MICHAEL
27 JACKSON’s sexual abuse of children, maintaining MICHAEL JACKSON’s image as an ethical
28 and wholesome entertainer, and securing their insured employment with DOE 1 and DOE 2. The
19
1 duty to disclose this information arose by the special, trusting, confidential, fiduciary, and/or in
2 loco parentis relationship between Defendants and Plaintiff.
3 59. Instead, Defendants ignored and/or concealed the sexual abuse of Plaintiff and
4 others by MICHAEL JACKSON that had already occurred, and continued to allow hundreds of
5 children, including the Plaintiff, to visit Defendants’ property, Neverland, and other properties,
6 and continue to be in contact with MICHAEL JACKSON, despite this knowledge of MICHAEL
7 JACKSON’s prior, sexually abusive acts towards minors. Plaintiff is informed and believes, and
8 on that basis alleges, that Defendants and each of them were given notice of incidents of
9 inappropriate conduct by MICHAEL JACKSON, including such facts as those set forth in this
10 Complaint.
11 60. Plaintiff is informed and believes, on that basis alleges, that prior to and during the
12 sexual harassment, molestation and abuse of Plaintiff, Defendants knew or had reason to know
13 that MICHAEL JACKSON had violated his role as a dancer, entertainer, teacher, mentor, coach,
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 and advisor to minors, and used this position of authority and trust acting on behalf of Defendants
Irvine, CA 92612
15 to gain access to children, including Plaintiff, on and off the premises and grounds of Defendants,
16 in which he caused Plaintiff to touch him, to allow him to touch Plaintiff in a sexual manner, and
17 engaged in sexual conduct and abuse, including harassment and molestation, with such children
18 including Plaintiff.
19 61. With actual or constructive knowledge that Defendant MICHAEL JACKSON had
20 previously engaged in dangerous and inappropriate conduct, including sexually abusing other
21 minors at Defendants DOE 1 and DOE 2’ owned and controlled properties, Defendants conspired
22 to and did knowingly fail to take reasonable steps, and failed to implement reasonable safeguards
23 to avoid acts of unlawful sexual conduct in the future by MICHAEL JACKSON, including, but
24 not limited to, preventing or avoiding placement of MICHAEL JACKSON in a function or
25 environment in which contact with children is an inherent aspect of that function or environment.
26 62. Plaintiff further alleges that Defendants failed to report and did hide and conceal
27 from the Plaintiff,, the Plaintiff’s parents, other minor children in their care (and parents of those
28 children), law enforcement authorities, civil authorities and others, the true facts and relevant
20
1 information necessary to bring MICHAEL JACKSON to justice for the sexual misconduct he
2 committed with minors, as well as to protect their fiduciaries, including Plaintiff.
3 63. Defendants also implemented various measures designed to, or which effectively,
4 made MICHAEL JACKSON's conduct harder to detect including, but not limited to:
5 a. Permitting MICHAEL JACKSON to remain in a position of authority and
trust after Defendants knew or had reason to know he was a molester of
6 children;
7 b. Placing MICHAEL JACKSON in a separate and secluded environment,
including placing him in charge of young boys, mentoring programs,
8 advising programs, coaching programs, and youth programs where they
purported to supervise the children, which allowed MICHAEL JACKSON
9 to sexually and physically interact with and abuse the children, including
Plaintiff;
10
c. Allowing MICHAEL JACKSON to come into contact with minors,
11 including Plaintiff, without adequate supervision;
12 d. Failing to inform, or concealing from Plaintiff's parents and law
enforcement officials the fact that Plaintiff and others were or may have
13 been sexually abused after Defendants knew or had reason to know that
Telephone: (949) 252-9990
MICHAEL JACKSON may have sexually abused Plaintiff or others,

ATTORNEYS AT LAW
14 thereby enabling Plaintiff to continue to be endangered and sexually

Irvine, CA 92612
abused, and/or creating the circumstance where Plaintiff and others were
15 less likely to receive medical/mental health care and treatment, thus
exacerbating the harm to Plaintiff;
16
e. Holding out MICHAEL JACKSON to Plaintiff and his parents, other
17 children and their parents, and to the community as being in good standing
and trustworthy;
18
f. Failing to take reasonable steps, and to implement reasonable safeguards to
19 avoid acts of unlawful sexual conduct by MICHAEL JACKSON with
students, who were minor children; and
20
g. Failing to put in place a system or procedure to supervise or monitor
21 employees, volunteers, representatives or agents to insure that they did not
molest or abuse minors in Defendants' care, including Plaintiff.
22
23 64. By his position within the Defendants' institutions, Defendants and MICHAEL
24 JACKSON demanded and required that Plaintiff respect MICHAEL JACKSON in his position of
25 dancer, entertainer, teacher, mentor, and advisor at Defendants DOE 1 and DOE 2.
26 65. Plaintiff is informed and believes, and on that basis alleges, that Defendants and
27 each of them, were or had reason to have been aware of MICHAEL JACKSON’s wrongful
28 conduct at or about the time it was occurring, and thereafter, but took no action to obstruct, inhibit
21
1 or stop such continuing conduct, or to help Plaintiff endure the trauma from such conduct.
2 Despite the authority and ability to do so, these Defendants negligently and/or willfully refused
3 to, and/or did not act effectively to stop the sexual assaults on Plaintiff, to inhibit or obstruct such
4 abuse, or to protect Plaintiff from the results of that trauma.
5 66. During the period of abuse of Plaintiff at the hands of MICHAEL JACKSON,
6 Defendants DOE 1 and DOE 2 had the authority and the ability to obstruct or stop MICHAEL
7 JACKSON's sexual assaults on Plaintiff, but negligently and/or willfully failed to do so, thereby
8 allowing the abuse to occur and to continue unabated. This failure was a part of Defendants' plan
9 and arrangement to conceal wrongful acts, to avoid and inhibit detection, to block public
10 disclosure, to avoid scandal, to avoid the disclosure of their tolerance of child sexual molestation
11 and abuse, to preserve a false appearance of propriety, and to avoid investigation and action by
12 public authority including law enforcement. Plaintiff is informed and believes, and on that basis
13 alleges, that such actions were motivated by a desire to protect the reputation of Defendants and
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 each of them, and to protect the monetary support of Defendants while fostering an environment
Irvine, CA 92612
15 where such abuse could continue to occur.

16 67. Plaintiff is informed and believes, and on that basis alleges, that at the time
17 MICHAEL JACKSON’s violations of the Penal Code and Civil Code alleged herein-above were
18 committed, Defendants knew or had reason to know, or were or were otherwise on notice of, prior
19 acts of childhood sexual abuse committed by MICHAEL JACKSON, and despite such knowledge
20 and/or notice, placed Plaintiff in MICHAEL JACKSON’s custody and/or made Plaintiff available
21 to MICHAEL JACKSON and then failed to take reasonable steps or implement reasonable
22 safeguards to protect Plaintiff from MICHAEL JACKSON’s acts of abuse. Plaintiff is further
23 informed and believes, and on that basis alleges, that these acts and/or omissions on the part of
24 Defendants were committed in spite of their ability to exercise control over the personal and
25 business affairs of MICHAEL JACKSON. Accordingly, Defendants are liable for MICHAEL
26 JACKSON’s acts of childhood sexual abuse in that their wrongful, intentional and/or negligent
27 acts were a legal cause of the childhood sexual abuse.
28 ///
22
1 DUTY OF DEFENDANTS
2 68. Defendants owed the Plaintiff a special duty of care. The Plaintiff, as a minor at all
3 relevant times alleged herein, was placed in the physical custody, control, and dominion of
4 Defendants and their agents, employees, and/or servants, and was placed in such custody, control,
5 and dominion in locations including, but not limited to: Neverland, the “Hideout”, and the
6 Havenhurst residence. The Plaintiff, as a minor in the custody, control, and under the dominion of
7 Defendants, stood in loco parentis with Defendants. As entities responsible for the custody,
8 supervision, care, and dominion of minor children in their care, Defendants owed the Plaintiff a
9 special duty of care, as they were entrusted with the Plaintiff’s safety, security and care. See
10 Pamela L. v. Farmer (1980) 112 Cal.App.3d 206, 211–12 (“In inviting the children to her home,
11 respondent assumed that special relationship. Respondent recognized that special duty and
12 relationship when she assured plaintiffs' parents it would be safe for them to play at her house.”)
13 FIRST CAUSE OF ACTION

Telephone: (949) 252-9990
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

ATTORNEYS AT LAW
14 (As To All Defendants)

Irvine, CA 92612
15 69. Plaintiff repeats, re-alleges and incorporates herein by reference paragraphs 1

16 through 68, inclusive, as though fully set forth herein.
17 70. Defendants' conduct towards the Plaintiff, as described herein, was outrageous and
18 extreme.
19 71. A reasonable person would not expect or tolerate Defendants’ putting MICHAEL
20 JACKSON in positions of authority at DOE 1, DOE 2, and DOES 3-50, which enabled
21 MICHAEL JACKSON to have access to minor children, including Plaintiff, so that he could
22 commit wrongful sexual acts with him, including the conduct described herein above. Plaintiff
23 held great trust, faith and confidence in Defendants, which, by virtue of Defendants' wrongful
24 conduct, turned to fear.
25 72. A reasonable person would not expect or tolerate Defendants to be incapable of
26 supervising and preventing employees of Defendants, including MICHAEL JACKSON, from
27 committing wrongful sexual acts with minor children in their charge, including Plaintiff, or to be
28 incapable of properly supervising MICHAEL JACKSON to prevent such abuse from occurring.
23
1 73. Defendants' conduct described herein was intentional and malicious and done for
2 the purpose of causing, or with the substantial certainty that it would cause Plaintiff to suffer
3 humiliation, mental anguish and emotional and physical distress.
4 74. As a result of the above-described conduct, Plaintiff suffered and continues to
5 suffer great pain of mind and body, shock, emotional distress, physical manifestations of
6 emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of
7 enjoyment of life; have suffered and continue to suffer and were prevented and will continue to
8 be prevented from performing daily activities and obtaining the full enjoyment of life; will sustain
9 loss of earnings and earning capacity, and have incurred and will continue to incur expenses for
10 medical and psychological treatment, therapy, and counseling.
11 75. In subjecting the Plaintiff to the wrongful treatment herein described, Defendants
12 DOE 1, DOE 2 and DOES 3-50, acted willfully and maliciously with the intent to harm Plaintiff,
13 and in conscious disregard of Plaintiff’s rights, so as to constitute malice and oppression under
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 California Civil Code section 3294. Plaintiff is therefore entitled to the recovery of punitive
Irvine, CA 92612
15 damages, in an amount to be determined by the court, against Defendants DOE 1, DOE 2 and
16 DOES 3 through 50, inclusive, in a sum to be shown according to proof.
17 SECOND CAUSE OF ACTION
NEGLIGENCE
18 (As to All Defendants)
21 77. As more fully set forth above, the conduct and actions of Defendants served to
22 create an environment in which MICHAEL JACKSON was afforded continuous access to
23 Plaintiff when she was a minor of 12-18 years. These actions include, but are not limited to:
24 arranging for Plaintiff and to stay with MICHAEL JACKSON, without her parents, present, on
25 numerous occasions; arranging for Plaintiff to be separated from her mother and family, and
26 ensuring that Plaintiff remained almost exclusively in MICHAEL JACKSON’s custody;
27 arranging for Plaintiff and MICHAEL JACKSON to be taken on shopping expeditions; and
28 arranging for Plaintiff to be transported with MICHAEL JACKSON on a regular basis.
24
1 78. As more fully set forth above, Defendants DOE 1, DOE 2 and Does 3 through 50,
2 inclusive, were aware and/or on notice of MICHAEL JACKSON’s proclivities for engaging in
3 sexual acts with minors prior to the first occasion on which Plaintiff was placed in MICHAEL
4 JACKSON’s custody through the acts of Defendants. Accordingly, at the time MICHAEL
5 JACKSON and Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, performed the
6 acts alleged herein, it was or should have been reasonably foreseeable to Defendants that by
7 continuously exposing and making Plaintiff available to MICHAEL JACKSON, Defendants were
8 placing Plaintiff in grave risk of being sexually abused by MICHAEL JACKSON. By knowingly
9 subjecting Plaintiff to such foreseeable danger, Defendants DOE 1, DOE 2 and DOES 3 through
10 50, inclusive, were duty-bound to take reasonable steps and implement reasonable safeguards to
11 protect Plaintiff from MICHAEL JACKSON. Furthermore, as alleged herein, Defendants DOE
12 1, DOE 2 and DOES 3 through 50, inclusive, at all times exercised a sufficient degree of control
13 over MICHAEL JACKSON’s personal and business affairs to prevent the acts of abuse by
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 keeping MICHAEL JACKSON away from Plaintiff. However, Defendants DOE 1, DOE 2 and
Irvine, CA 92612
15 DOES 3 through 50, inclusive, failed to take any reasonable steps or implement any reasonable
16 safeguards for Plaintiff’s protection whatsoever, and continued to make Plaintiff accessible to
17 MICHAEL JACKSON for the purposes of sexual abuse.
18 NEGLIGENCE PER SE—PENAL CODE MANDATORY CHILD ABUSE REPORTING
19 79. Under the Child Abuse and Neglect Reporting Act, Defendants DOE 1, DOE 2
20 and DOES 3 through 50, inclusive, were child care custodians and were under a statutory duty to
21 report known or suspected incidents of sexual molestation or abuse of minors to a child protective
22 agency, pursuant to California Penal Code § 11166, and/or not to impede the filing of any such
23 report. Furthermore, Defendants DOE 1 and DOE 2 were under a statutory duty to provide their
24 employees with various acknowledgements of reporting requirements under Penal Code
25 §11166.5.
26 80. Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, knew or had reason
27 to know that their agent, employee, counselor, advisor and mentor, MICHAEL JACKSON, had
28 sexually molested, abused or caused touching, battery, harm, and other injuries to minors,
25
1 including Plaintiff, giving rise to a duty to report such conduct under California Penal Code
2 §11166.
3 81. Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, knew, or had
4 reason to know of in the exercise of reasonable diligence, that an undue risk to minors, including
5 the Plaintiff, existed because Defendants DOE 1 and DOE 2 did not comply with California's
6 mandatory reporting requirements.
7 82. By failing to report the continuing molestations and abuse, which Defendants DOE
8 1, DOE 2 and DOES 3 through 50, inclusive, knew of or had reason to known of, and by ignoring
9 the fulfillment of the mandated compliance with the reporting requirements provided under
10 California Penal Code § 11166, Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive,
11 created the risk and danger contemplated by the Child Abuse and Neglect Reporting Act
12 (hereinafter “CANRA”), and as a result, unreasonably and wrongfully exposed Plaintiff and other
13 minors to sexual molestation and abuse.

Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 83. The Plaintiff was a member of the class of persons for whose protection California
Irvine, CA 92612
15 Penal Code § 11166 was specifically adopted to protect.

16 84. Had Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, adequately
17 reported the molestation of Plaintiff and other minors as required by California Penal Code §
18 11166, further harm to Plaintiff and other minors would have been avoided.
19 85. As a proximate result of Defendants DOE 1, DOE 2 and DOES 3 through 50’s,
20 inclusive, failure to follow the mandatory reporting requirements of California Penal Code §
21 11166, Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, wrongfully denied the
22 Plaintiff and other minors the intervention of child protection services. Such public agencies
23 would have changed the then-existing arrangements and conditions that provided the access and
24 opportunities for the molestation of Plaintiff by MICHAEL JACKSON.
25 86. The physical, mental, and emotional damages and injuries resulting from the
26 sexual molestation of Plaintiff by MICHAEL JACKSON, were the type of occurrence and
27 injuries that the CANRA was designed to prevent.
28
26
1 87. As a result, Defendants DOE 1, DOE 2 and DOES 3 through 50’s, inclusive,
2 failure to comply with the mandatory reporting requirements of California Penal Code § 11166
3 also constituted a per se breach of Defendants’ DOE 1, DOE 2 and DOES 3 through 50's,
4 inclusive duties to Plaintiff.
5 88. As a direct and proximate result of the failure of Defendants DOE 1, DOE 2 and
6 DOES 3 through 50, inclusive, to protect Plaintiff from the acts of childhood sexual abuse to
7 which she was subjected by MICHAEL JACKSON, Plaintiff has suffered and will continue to
8 suffer (a) severe mental and emotional distress including, but not limited to, severe anxiety,
9 stress, anger, fear, low self-esteem, shame, humiliation, depression and physical distress; (b)
10 expenses for mental health professionals and other medical treatment; and (c) loss of past and
11 future earnings and other economic benefits according to proof at the time of trial.
12 THIRD CAUSE OF ACTION
NEGLIGENT SUPERVISION

Telephone: (949) 252-9990
ATTORNEYS AT LAW

Irvine, CA 92612

16 90. By virtue of Plaintiff's special relationship with Defendants DOE 1, DOE 2 and
17 DOES 3 through 50, inclusive,, and Defendants DOE 1, DOE 2 and DOES 3 through 50’s,
18 inclusive, relation to MICHAEL JACKSON, Defendants DOE 1, DOE 2 and DOES 3 through
19 50, inclusive, owed Plaintiff a duty to provide reasonable supervision of MICHAEL JACKSON,
20 to use reasonable care in investigating MICHAEL JACKSON's background, and to provide
21 adequate warning to the Plaintiff, and other children, of MICHAEL JACKSON’s dangerous
22 propensities and unfitness.
23 91. Plaintiff is informed and believes, and on that basis alleges, that Defendants DOE
24 1, DOE 2 and DOES 3 through 50, inclusive, by and through their respective agents, servants and
25 employees, knew or had reason to know of MICHAEL JACKSON’s dangerous and exploitive
26 propensities and/or that MICHAEL JACKSON was an unfit agent. Despite such knowledge,
27 Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, negligently failed to supervise
28 MICHAEL JACKSON in his position of trust and authority as an authority figure and supervisor
27
1 of children, where he was able to commit wrongful acts against the Plaintiff. Defendants DOE 1,
2 DOE 2 and DOES 3 through 50, inclusive, failed to provide reasonable supervision of MICHAEL
3 JACKSON, failed to use reasonable care in investigating MICHAEL JACKSON, and failed to
4 provide adequate warning to Plaintiff of MICHAEL JACKSON’s dangerous propensities and
5 unfitness. Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, further failed to take
6 reasonable measures to prevent sexual abuse harassment, and molestation of children, including
7 Plaintiff.
9 1, DOE 2 and DOES 3 through 50, inclusive, were put on notice, and knew or had reason to
10 know, that MICHAEL JACKSON had previously engaged and was continuing to engage in
11 unlawful sexual conduct with children and committed other felonies, for his own personal
12 gratification, and that it was, or should have been foreseeable that he was engaging, or would
13 engage in illicit sexual activities with Plaintiff, and others, under the cloak of his authority,
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 confidence, and trust, bestowed upon him through Defendants DOE 1, DOE 2 and DOES 3
Irvine, CA 92612
15 through 50, inclusive, and each of them.

17 1, DOE 2 and DOES 3 through 50, inclusive, were placed on actual and/or constructive notice
18 that, MICHAEL JACKSON had children prior to, and/or during the time he was in contact with
19 the Plaintiff. Plaintiff is informed, and thereon alleges, that Defendants DOE 1, DOE 2 and DOES
20 3 through 50, inclusive, were informed of sexual abuse, harassment and molestations committed
21 by MICHAEL JACKSON or of conduct that would put a reasonable person on notice of such
22 propensity to abuse, harassment and molestation.
23 94. Even though Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, knew
24 or had reason to know of these activities by MICHAEL JACKSON, Defendants DOE 1, DOE 2
25 and DOES 3 through 50, inclusive, did nothing to investigate, supervise or monitor MICHAEL
26 JACKSON to ensure the safety of the guests.
27 95. As an institution entrusted with the care of minors, where staff, employees, agents,
28 and management, such as the MICHAEL JACKSON were placed in contact with minors,
28
1 Defendants DOE 1, DOE 2 and DOES 3 through 50's expressly and implicitly represented that
2 these individuals, including MICHAEL JACKSON, were not a sexual threat to children and
3 others who would fall under MICHAEL JACKSON's influence, control, direction, and guidance.
4 96. Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, negligently failed
5 to supervise MICHAEL JACKSON in his positions of trust and authority as an employee, agent,
6 counselor and mentor, and/or other authority figure, where MICHAEL JACKSON was able to
7 commit wrongful acts against the Plaintiff. Defendants DOE 1, DOE 2 and DOES 3 through 50,
8 inclusive, failed to provide reasonable supervision of MICHAEL JACKSON. Defendants DOE 1,
9 DOE 2 and DOES 3 through 50 further failed to take reasonable measures to prevent sexual
10 harassment, molestation and abuse of minors, including the Plaintiff.
11 97. At no time during the periods of time alleged did Defendants’ DOE 1, DOE 2 and
12 DOES 3 through 50, inclusive, have in place a system or procedure to reasonably investigate,
13 supervise and monitor individuals in contact with minor children, including MICHAEL
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 JACKSON, to prevent pre-sexual grooming and sexual harassment, molestation and abuse of
Irvine, CA 92612
15 children, nor did they implement a system or procedure to oversee or monitor conduct toward
16 minors, students and others in Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive,
17 care.
18 98. Defendants’ DOE 1, DOE 2 and DOES 3 through 50, inclusive, were or should
19 have known to be aware and understand how vulnerable children were to sexual harassment,
20 molestation and abuse by mentors, advisors, and other persons of authority within Defendants
21 DOE 1, DOE 2 and DOES 3 through 50, inclusive.
22 99. Defendants DOE 1, DOE 2 and DOES 3 through 50’s, inclusive, conduct was a
23 breach of their duties to the Plaintiff.
24 100. Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, breached their duty
25 to the Plaintiff by, inter alia, failing to adequately monitor and supervise MICHAEL JACKSON
26 and stopping MICHAEL JACKSON from committing wrongful sexual acts with minors
27 including the Plaintiff. This belief is founded on the fact that employees and staff of Defendants
28 DOE 1, DOE 2 and DOES 3 through 50, inclusive, including had suspected the abuse was
29
1 occurring at the time, and failed to investigate into the matter further. Based on these facts,
2 Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, knew or had reason to know of
3 MICHAEL JACKSON's incapacity to supervise and stop employees of Defendants DOE 1, DOE
4 2 and DOES 3 through 50, inclusive from committing wrongful sexual acts with minors.
5 101. As a result of the above-described conduct, Plaintiff has suffered and continues to
7 emotional distress, embarrassment, loss of self-esteem, disgrace, humiliations, and loss of
8 enjoyment of life; has suffered and continues to suffer and was prevented and will continue to be
9 prevented from performing daily activities and obtaining the full enjoyment of life; will sustain
10 loss of earnings and earning capacity, and/or has incurred and will continue to incur expenses for
12 FOURTH CAUSE OF ACTION
NEGLIGENT RETENTION/HIRING

Telephone: (949) 252-9990
ATTORNEYS AT LAW

Irvine, CA 92612

16 103. By virtue of Plaintiff's special relationship with Defendants DOE 1, DOE 2 and
17 DOES 3 through 50, inclusive and each of them, and Defendants DOE 1, DOE 2 and DOES 3
18 through 50’s, inclusive, relation to MICHAEL JACKSON, Defendants DOE 1, DOE 2 and
19 DOES 3 through 50, inclusive, owed Plaintiff a duty to not hire and/or retain MICHAEL
20 JACKSON, given his dangerous and exploitive propensities, which Defendants DOE 1, DOE 2
21 and DOES 3 through 50, inclusive, knew or had reason to know had they engaged in a
22 meaningful and adequate investigation of his background prior to his hiring.
23 104. As an institution entrusted with the care of minors, where staff, employees, agents,
24 and management, such as the MICHAEL JACKSON were placed in contact with minors,
25 Defendants DOE 1, DOE 2 and DOES 3 through 50's, inclusive, expressly and implicitly
26 represented that these individuals, including MICHAEL JACKSON, were not a sexual threat to
27 children and others who would fall under MICHAEL JACKSON 's influence, control, direction,
28 and guidance.
30
1 105. Plaintiff is informed and believes, and on that basis alleges, that at no time during
2 the periods of time alleged did Defendants DOE 1, DOE 2 and DOES 3 through 50's, inclusive,
3 have in place a system or procedure to reasonably investigate, supervise and/or monitor those
4 individuals in direct contact with children, including MICHAEL JACKSON, to prevent pre-
5 sexual grooming and/or sexual harassment, molestation and abuse of patrons, nor did they
6 implement a system or procedure to oversee or monitor conduct toward patrons and others in
7 Defendants DOE 1, DOE 2 and DOES 3 through 50's, inclusive, care.
8 106. Defendants DOE 1, DOE 2 and DOES 3 through 50's, inclusive, and each of them
9 were or should have been aware and understood how vulnerable minor children were to sexual
10 abuse, harassment and molestation by persons of authority, including the MICHAEL JACKSON,
11 within the control of Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive.
12 107. Plaintiff is informed and believes and on that basis alleges other children and/or
13 employees of Defendants DOE 1, DOE 2 and DOES 3 through 50's, inclusive, complained of
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 MICHAEL JACKSON’s sexual improprieties prior to the sexual abuse of the Plaintiff. Either
Irvine, CA 92612
15 Defendants DOE 1, DOE 2 and DOES 3 through 50's, inclusive, knew, or at the very least should
16 have had reason to know of MICHAEL JACKSON’s prior criminal history of sexual misconduct
17 with guests prior to Plaintiff’s abuse.
18 108. Plaintiff is informed, and believes, and on that basis alleges, that the Defendants
19 DOE 1, DOE 2 and DOES 3 through 50, inclusive, were put on notice, and should have known
20 that MICHAEL JACKSON had previously engaged and continued to engage in unlawful sexual
21 conduct with patrons and other felonies, for his own personal gratification, and that it was, or
22 should have been foreseeable that he was engaging, or would engage in illicit sexual activities
23 with Plaintiff, and others, under the cloak of his authority, confidence, and trust, bestowed upon
24 him through Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive.
25 109. Plaintiff is informed and believes, and on that basis alleges that Defendants DOE
26 1, DOE 2 and DOES 3 through 50's, inclusive, were placed on actual and/or constructive notice
27 that MICHAEL JACKSON had abused, harassed, molested and/or was molesting minor children,
28 both before his sexual abuse, molestation and harassment of the Plaintiff, and during that same
31
1 period. Plaintiff is informed, and thereon alleges, that other third parties, patrons, and/or law
2 enforcement officials informed Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, of
3 inappropriate conduct and molestations committed by MICHAEL JACKSON.
4 110. Even though Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, knew
5 or had reason to know of these activities by MICHAEL JACKSON, Plaintiff is informed that
6 Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, failed to use reasonable care in
7 investigating MICHAEL JACKSON and did nothing to investigate, supervise or monitor
8 MICHAEL JACKSON to ensure the safety of the other minor children in his charge, including
9 the Plaintiff.
10 111. Defendants DOE 1, DOE 2 and DOES 3 through 50’s, inclusive, conduct was a
11 breach of their duties to the Plaintiff.
Telephone: (949) 252-9990
ATTORNEYS AT LAW

Irvine, CA 92612
19 FIFTH CAUSE OF ACTION
NEGLIGENT FAILURE TO TRAIN, WARN OR EDUCATE
23 114. Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive owed Plaintiff a
24 duty to take reasonable protective measures to protect Plaintiff and other minor children in their
25 charge from the risk of sexual abuse, harassment and molestation by MICHAEL JACKSON by
26 properly warning, training or educating the Plaintiff and other minors about how to avoid such a
27 risk.
28 115. Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, breached their duty
32
1 to take reasonable protective measures to protect Plaintiff and other minor children in their
2 charge, from the risk of sexual abuse, harassment and molestation by MICHAEL JACKSON,
3 such as the failure to properly warn, train or educate Plaintiff and other minor children in their
4 charge about how to avoid such a risk.
5 116. Defendants breached their duty to take reasonable protective measures to protect
6 Plaintiff and other minor children in their charge from the risk of sexual harassment, molestation
7 and abuse by MICHAEL JACKSON, by failing to supervising and/or stop employees of
8 Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, including MICHAEL JACKSON,
9 from committing wrongful sexual acts with minor children, including Plaintiff.
Telephone: (949) 252-9990
ATTORNEYS AT LAW
Irvine, CA 92612
17 SIXTH CAUSE OF ACTION
BREACH OF FIDUCIARY DUTY
21 119. As set forth more fully above, Defendants DOE 1, DOE 2 and DOES 3 through
22 50, inclusive, in concert with MICHAEL JACKSON, recruited, enticed, and encouraged Plaintiff
23 and Plaintiff’s mother to give their trust and confidence to Defendants and MICHAEL JACKSON
24 so that Plaintiff could be taken from her mother’s care and supervision and placed under the care
25 and supervision of Defendants and MICHAEL JACKSON. In so doing, Defendants DOE 1, DOE
26 2 and DOES 3 through 50, inclusive, entered into a fiduciary relationship with Plaintiff whereby
27 Defendants owed Plaintiff an in loco parentis duty of care to take all reasonable steps and
28
33
1 implement all reasonable safeguards to protect Plaintiff while she was in the custody of
2 Defendants and/or MICHAEL JACKSON.
3 120. Plaintiff and her mother agreed to place their trust and confidence in Defendants
4 DOE 1, DOE 2 and DOES 3 through 50, inclusive, in the expectation that Defendants would
5 properly supervise Plaintiff, regulate her activities and behavior, and ensure her safety. Further,
6 Plaintiff and her mother agreed to this because they believed in the integrity of Defendants DOE
7 1, DOE 2 and DOES 3 through 50, inclusive, and therefore felt comfortable in entrusting the
8 minor Plaintiff to the care and custody of Defendants.
9 121. As alleged herein, MICHAEL JACKSON breached his duty to Plaintiff by
10 repeatedly subjecting Plaintiff to acts of childhood sexual abuse. As further alleged herein,
11 Defendants DOE 1, DOE 2 and DOES 3 through 50, inclusive, breached this duty to Plaintiff by
12 failing to take any reasonable steps or implement any reasonable safeguards to protect Plaintiff
13 from MICHAEL JACKSON, and by allowing Plaintiff to be sexually abused by MICHAEL

Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 JACKSON on a regular basis.

Irvine, CA 92612
15 122. As a direct and proximate result of Defendants’ DOE 1, DOE 2 and DOES 3
16 through 50, inclusive, breach of their fiduciary duty to Plaintiff, Plaintiff has suffered and will
17 continue to suffer (a) severe mental and emotional distress including, but not limited to, severe
18 anxiety, stress, anger, fear, low self-esteem, shame, humiliation, depression and physical distress;
19 (b) expenses for mental health professionals and other medical treatment; and (c) loss of past and
20 future earnings and other economic benefits according to proof at the time of trial.
21 PRAYER FOR RELIEF
22 Wherefore, Plaintiff prays for Judgment against Defendants as follows:
23 1. For past, present and future general damages in an amount to be determined at
24 trial;
25 2. For past, present and future special damages, including but not limited to past,
26 present and future lost earnings, economic damages and others, in an amount to be
27 determined at trial;
28 3. Any appropriate punitive or exemplary damages against Defendants;
34
1 4. Any appropriate statutory damages;
2 5. For costs of suit;
3 6. For interest as allowed by law;
4 7. For attorney's fees pursuant to California Code of Civil Procedure § 1021.4,
5 1021.5, or otherwise as allowable by law; and
6 8. For such other and further relief as the court may deem proper.
7 Dated: October 19, 2016 MANLY, STEWART & FINALDI
8 By: _______________________________
VINCE WILLIAM FINALDI, Esq.
9 Attorneys of Record for Plaintiff,
10 JANE AA DOE.
11
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Telephone: (949) 252-9990
ATTORNEYS AT LAW
14
Irvine, CA 92612
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1 DEMAND FOR JURY TRIAL
2 A trial by Jury is hereby demanded by Plaintiff.
3 Dated: October 19, 2016 MANLY, STEWART & FINALDI
4 By: _______________________________
VINCE WILLIAM FINALDI, Esq.
5 Attorneys of Record for Plaintiff,
JANE AA DOE.
6
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Telephone: (949) 252-9990
ATTORNEYS AT LAW
14
Irvine, CA 92612
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Jane Doe Complaint

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1 JOHN C. MANLY, Esq. (State Bar No.

8 COUNTY OF LOS ANGELES, CENTRAL DISTRICT

11 Plaintiff, COMPLAINT FOR DAMAGES FOR:

12 vs. (1) INTENTIONAL INFLICTIONOF

13 DOE 1, a California corporation; DOE 2, a

14 inclusive, (4) NEGLIGENT RETENTION/HIRING;

(5) NEGLIGENT FAILURE TO WARN,

18 DEMAND FOR JURY TRIAL

COMPLAINT FOR DAMAGES

15 June 25, 2009, at the age of fifty (50).

15 engaging in childhood sexual abuse of Plaintiff and others.

13 MICHAEL JACKSON was grooming Plaintiff for sexual abuse.

13 PENAL CODE AND CIVIL CODE VIOLATIONS

13 * Duty to ensure that personnel are actually on hand and supervising

* Duty to provide enough supervision to minor children, including the

14 accommodation to an injured person or on his behalf to others... because of an injury or death

MICHAEL JACKSON may have sexually abused Plaintiff or others,

14 thereby enabling Plaintiff to continue to be endangered and sexually

15 where such abuse could continue to occur.

13 FIRST CAUSE OF ACTION

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

14 (As To All Defendants)

15 69. Plaintiff repeats, re-alleges and incorporates herein by reference paragraphs 1

13 minors to sexual molestation and abuse.

15 Penal Code § 11166 was specifically adopted to protect.

13 (As to All Defendants)

14 89. Plaintiff repeats, re-alleges and incorporates herein by reference paragraphs 1

15 through 88, inclusive, as though fully set forth herein.

15 through 50, inclusive, and each of them.

13 (As to All Defendants)

14 102. Plaintiff repeats, re-alleges and incorporates herein by reference paragraphs 1

15 through 101, inclusive, as though fully set forth herein.

14 emotional distress, embarrassment, loss of self-esteem, disgrace, humiliations, and loss of

13 from MICHAEL JACKSON, and by allowing Plaintiff to be sexually abused by MICHAEL

14 JACKSON on a regular basis.

3 Dated: October 19, 2016 MANLY, STEWART & FINALDI

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