1 Palak Chopra, State Bar #225048

201 South Anita Drive, Suite 202

2 Orange, California 92868
Tele: (714) 496-1327
3
Fax: (714) 464-2387
4
Attorney for Plaintiff: MICHAEL DANLEY
5

8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA

COUNTY OF ORANGE
9
CENTRAL JUSTICE CENTER
10

11 ) CASE NO:
MICHAEL DANLEY, an individual;
)
12 )
)
13 Plaintiff, ) PLAINTIFFS’ COMPLAINT FOR:
14
)
vs. ) 1) ASSAULT;
)
15
ANTHONY GEISLER, an individual; and ) 2) NEGLIGENT INFLECTION OF
DOES 1 to 100 INCLUSIVE , ) EMOTIONAL DISTRESS;
3) INTENTIONAL INFLECTION OF
16
)
17 Defendants. ) EMOTIONAL DISTRESS;
.

)
18
)
)
19
)
)
20
)
)
21 )
)
22 )
23

24 COMES NOW plaintiff MICHAEL DANLEY, an individual (“Danley” or “Plaintiff”) and

25 alleges against defendant ANTHONY GEISLER, an individual (“Geisler” or “Defendant”), and
26 DOES 1 to 100 INCLUSIVE (collectively Geisler and DOES 1 to 100 Inclusive shall be referred to as
27 “Defendants”), as follows:
28

-1-
________________________________________________________________________________________________________ .
Complaint
 1
THE PARTIES
2
1. Plaintiff Michael Danley is and at all times relevant herein, an individual residing in the
3
State of California, County of Orange, as is a registered process server with the State of California,
4
County of Orange. Danley has been a process server for over 25 years and has made over 100,000
5
serves during that time.
6
2. Defendant Anthony Geisler is and at all times relevant herein, an individual residing in
7
the State of California, County of Orange, and was the former President of L.A. Boxing Franchise
8
Corp. and is currently the UFC Gym franchising president after UFC Gym purchased L.A. Boxing.
9
3. Plaintiff is ignorant of the true names and capacities of the defendants sued herein as
10
DOES 1 to 100, inclusive, and therefore, sue these defendants by such fictitious names. Plaintiff will
11
amend this complaint to allege their true names and capacities when ascertained.
12
4. Plaintiff alleges that each of the defendants designated in this complaint as DOE was
13 and is responsible liable and/or obligated to Plaintiff in some manner in connection with the events,
14 occurrences, happenings, and transactions alleged in this complaint, and that Plaintiff’s damages as
15 alleged in this complaint were proximately caused by these defendants. Each defendant is, and at all
16 times herein mentioned was, an agent, employee, joint venturer, shareholder, director, member, co-
17 conspirator, master or partner, insurer, of each other defendants, and in doing the things herein
18 described was acting within the scope of her, his or its actual or apparent authority, or within the scope
19 of each conspiracy and with the knowledge and ratification of the remaining defendants.
20

21 JURISDICTION AND VENUE

22 5. This Court has jurisdiction over the Defendants as the Defendants are all believed to be
23 residents of the State of California, County of Orange.
24 6. Venue it proper in this Court pursuant to California Code of Civil Procedure §§395 and
25 395.5 because the actions stated herein took place in Orange County, California.
26 //
27 //
28 //

-2-
________________________________________________________________________________________________________ .
Complaint
 1

2 PRELIMINARY FACTS AND ALLEGATIONS

3 7. On or about November 4th, 2011 at approximately 7:30-7:45 p.m. Danley went to go
4 serve Defendant with some legal notices including a 3 day notice to cure breach of covenants or quit; 3
5 day notice to pay rent or quit; notice of belief of abandonment of real property, and notice of non-
6 renewal, for real property located at: 5144 Scholarship, Irvine, California 92612 (“Scholarship
7 Property”).
8 8. Defendant is believed to have moved out of the Scholarship Property without paying his
9 full rent and without giving a proper notice that he was leaving. Defendant was going to be asked to
10 leave the Scholarship Property because he became difficult to work with and problematic tenant.
11 9. Veronica Hicks the real estate broker who was managing the Scholarship Property, was
12 able to help track Defendant down to a new home located at: 75 Shady Canyon Drive, Irvine,
13 California 92603 (“Premises”). Danley was instructed to go to the Premises to serve Defendant with
14 the above-mentioned notices to insure that all legal requirements for reclaiming the Scholarship
15 Property from Defendant were met.
16 10. The Premises is located in a guard gated community, and a guard for the community in
17 which the Premises is located followed Danley up to the Premises in his own vehicle.
18 11. Upon approaching the Premises Danley saw that the garage was open, the garage lights
19 were on, and that delivery and/or movers were delivering and/or moving personal property into the
20 Premises.
21 12. Danley also saw that the lights were off near the front door to the Premises.
22 13. Danley approached the delivery men/movers and asked if they could get Anthony
23 Geisler for him. The delivery men/movers agreed and went inside the Premises and later returned to
24 move some chairs into the Premises.
25 14. Danley waited just outside the garage on the driveway as the delivery men/movers were
26 inside.
27 15. Shortly thereafter Defendant walked out into the lit garage and stood with his left foot
28 in front of his right in a fighting stance, with his right hand behind his back.

-3-
________________________________________________________________________________________________________ .
Complaint
 1
16. Danley then stated to Defendant “Hello sir I have these court documents for you.”
2
17. As Danley stated these words Defendant displayed a silver firearm with black grips
3
with his right arm and told Danley to get off his property.
4
18. Danley told Defendant that he was a process server for the court and had court
5
documents for Defendant. Defendant then pointed his firearm at Danley’s feet and told Danley “I
6
don’t care get off my property.” Defendant also stated “Get out of here or I’ll fucking kill you.”
7
19. Danley dropped the paperwork on the ground and told Defendant that he was leaving.
8
20. As Danley was leaving he was afraid that he was going to be shot in the back.
9
Meanwhile Defendant was yelling “You’re trespassing get out now.”
10
21. Danley walked back to his car where the security guard remained and they both drove
11
back down to the guard house and waited for police to arrive as Danley called Irvine Police while
12
driving back down to the guard house.
13
22. Danley gave police an account of what happened and officers tried to contact Defendant
14
via telephone and via ringing the doorbell and knocking at the front door. Defendant refused to answer
15
his cell phone or open the front door for police officers despite most likely being home.
16
23. Police officers did in fact find the delivery truck and spoke with the delivery personal
17
who confirmed that they were approached by Danley to get Defendant, but did not hear or see anything
18
as they were inside the Premises when Defendant pointed his gun at Danley.
19
24. At approximately 9:05 p.m on this same night Defendant called Irvine Police
20
Department’s non-emergency line and the call was transferred to one of the Irvine Police Department
21
officers who were at the scene taking a report from Danley and the delivery men.
22
25. Defendant admitted that he armed himself with a Beretta 92FS 9mm handgun with a
23
silver finish and black grips and that he held the gun behind his back with his right hand as he walked
24
into his garage.
25
26. Defendant then lied to police and told the office handling the report that he took the gun
26
with him because he found the fact that there was an unknown man in his garage unsettling.
27
Defendant also stated that the garage was unlit when the garage lights were on, but the front door lights
28
were off, and that he did not know how to operate the garage lights.

-4-
________________________________________________________________________________________________________ .
Complaint
 1
27. Defendant then told an Irvine Police Department officer that Danley was inside the
2
garage when he first saw him, when Danley was outside the garage the entire time.
3
28. Defendant then lied again to the officer and stated that he was holding the firearm down
4
to his side. If Defendant had been holding the firearm down his side then Danley would not have been
5
able to give officers an accurate description of the firearm which was in fact pointed at Danley.
6
29. Defendant also told the reporting police officer that there was “no round chambered,”
7
which is also believed to have been a lie, as there is no point in taking out a gun with no bullets, and
8
because it is believed that Defendant had made many enemies due to his shady business practices and
9
poor personality.
10
30. Defendant is believe to try to portray himself as a tough guy and a martial arts expert,
11
and is once believed to have challenged R & B singer Chris Brown to a fight via starting a Facebook
12
page called “I Want To Fight Chris Brown.” However, the truth is that Defendant is believed to be a
13
coward who needs a gun to protect himself from someone just trying to serve him legal papers.
14
31. Defendant is later believed to have worked out a plea deal with the Orange County
15
District Attorney to avoid jail time over the incident.
16
32. Danley believes and thereon alleges that due to Defendant’s business practices and
17
personality that Defendant knew he was a target for hostility and thus had to arm himself with a
18
firearm, even after moving to a guard gated community and having delivery men tell him that someone
19
was asking for him by name outside.
20

21
FIRST CAUSE OF ACTION FOR ASSULT
22
33. Danley repeats and re-alleges each and every allegation set forth in Paragraphs 1
23
through 32 above as fully set forth herein.
24
34. Defendant intentionally raised a firearm at Danley and told Danley ““I don’t care get off
25
my property;” “Get out of here or I’ll fucking kill you;” and “You’re trespassing get out now.”
26
35. The actions of pointing a firearm at someone and telling an unarmed process server just
27
trying to deliver court documents is harmful and offensive.
28

-5-
________________________________________________________________________________________________________ .
Complaint
 1
36. Defendant’s actions of pointing the firearm at Danley and yelling at Danley were non-
2
consensual and caused damage to Danley.
3
37. Wherefore, Danley seeks damages as further set below.
4

5
SECOND CAUSE OF ACTION FOR
6
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
7
38. Danley repeats and re-alleges each and every allegation set forth in Paragraphs 1
8
through 37 above as fully set forth herein.
9
39. Defendant’s conduct of pointing a firearm at Danley and yelling at him were
10
outrageous, given the fact that there was plenty of light in the area, and that Defendant could plainly
11
see and hear that Danley was just trying to give him some legal papers.
12
40. Defendant acted with intent to cause injury or knowledge that injury was substantially
13
certain to result from his conduct.
14
41. Defendant’s outrageous conduct was directed at Danley as they were the only two
15
people at the scene of the assault.
16
42. Defendant’s actions caused Danley sever emotional distress.
17
43. Danley’s emotional distress was caused by Defendant’s above-mentioned actions.
18
44. Wherefore, Danley seeks damages as further set below.
19

20
THIRD CAUSE OF ACTION FOR
21
NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
22
45. Danley repeats and re-alleges each and every allegation set forth in Paragraphs 1
23
through 44 above as fully set forth herein.
24
46. Defendant owed Danley a duty to peacefully accept the legal documents he was trying
25
to serve him, without pointing a firearm at Danley or yelling at Danley.
26
47. As a result of Defendant pointing a firearm at Danley and yelling at Danley, Danley
27
suffered serious emotional distress.
28
48. Wherefore, Danley seeks damages as further set below.

-6-
________________________________________________________________________________________________________ .
Complaint
 1
WHEREFORE, Plaintiff demands judgment from Defendant as follows:
2
First Cause of Action for Assault
3
1. Compensatory damages to be proven at trial, but not less than $250,000.00;
4
2. Emotional distress damages to be proven at trial, but not less than $250,000.00;
5
3. Punitive damages pursuant to California Civil Code §3294;
6
4. Attorney’s fees and costs pursuant to California Code of Civil Procedure §1021 et seq.; and
7
5. Such other relief as the Court may consider proper.
8

9
Second Cause of Action For Intentional Infliction Of Emotional Distress
10
1. Compensatory damages to be proven at trial, but not less than $250,000.00;
11
2. Punitive damages pursuant to California Civil Code §3294;
12
3. Costs; and
13
4. Such other relief as the Court may consider proper.
14

15
Third Cause of Action For Negligent Infliction of Emotional Distress
16 1. Compensatory damages to be proven at trial, but not less than $250,000.00;
17 2. Punitive damages pursuant to California Civil Code §3294;
18 3. Costs; and
19 4. Such other relief as the Court may consider proper.
20

21 November 1, 2013
22 Palak Chopra
23 Palak Chopra, Esq.
Attorney For Plaintiff,
24 MICHALE DANLEY
25

26

27

28

-7-
________________________________________________________________________________________________________ .
Complaint