12345678910111213141516171819202122232425262728Victor L. George, State Bar No. 110504Meylin P. Alfaro, State Bar No. 315177LAW OFFICES OF VICTOR L. GEORGE22760 Hawthorne Blvd., Suite 200Torrance, California 90505Telephone:(310) 698-0990Facsimile:(310) 698-0995E-Mail: vgeorge@vgeorgelaw.commalfaro@vgeorgelaw.comAttorneys for Plaintiff,A. GOERTZ

SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELES

A. GOERTZ, an individual, Plaintiff, v.PUBG SANTA MONICA, INC., a businessentity, form unknown; PUBG ENTERTAINMENT, INC., a business entity, form unknown; KRAFTON, INC., a business entity, formunknown;STRIKING DISTANCE STUDIOS, INC., aCalifornia corporation;KRAFTON VENTURES FUND, L.P., a business entity, form unknown; KRAFTON VENTURES, INC., a businessentity, form unknown; KRAFTON VENTURES, L.L.C., a business entity, form unknown; KRAFTON AMERICAS, INC., a businessentity, form unknown; KEVIN KIMBALL, an individual; andDOES 1 through 100, inclusive, Defendants.CASE NO.

COMPLAINT FOR DAMAGES

1.HARASSMENT (SEX);2. DISCRIMINATION IN VIOLATION OF FEHA,

CALIFORNIA GOVERNMENT CODE 

 §§12900,

et seq.

:A. GENDER 3. VIOLATION OF PUBLIC POLICY;4.RETALIATION;5.INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS;6. FALSE IMPRISONMENT.

DEMAND FOR JURY TRIAL

Plaintiff A. GOERTZ, hereby complains and alleges against Defendants, and eachof them, as follows:

1COMPLAINT FOR DAMAGES

 

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PRELIMINARY FACTUAL INFORMATION

1.Plaintiff A. GOERTZ (hereinafter referred to as “Plaintiff”), is and at all timesmentioned herein, was an individual and a resident of the County of Los Angeles, State of California.2.Plaintiff is informed and believes that Defendant PUBG SANTA MONICA,INC. (hereinafter “PUBG”) is a business entity, form unknown, and at all times mentionedherein, was and is authorized to do business in Los Angeles County, in the State of California. Its principal place of business is located at 1601 Cloverfield Blvd., Suite 5000N,Santa Monica, California 90404 in Los Angeles County, State of California, and was solocated during all pertinent times referred to herein. 3.Plaintiff is informed and believes that Defendant PUBG ENTERTAINMENT,INC. (hereinafter “PUBG ENTERTAINMENT”) is a business entity, form unknown, and atall times mentioned herein, was and is authorized to do business in the State of California.Its principal place of business is located at 6111 Bollinger Canyon Road, Suite 150, SanRamon, California 94583 in Contra Costa County, State of California, and was so locatedduring all pertinent times referred to herein. 4.Plaintiff is informed and believes that Defendant KRAFTON, INC.(hereinafter “KRAFTON”) is a business entity, form unknown, and at all times mentionedherein, was and is authorized to do business in the State of California. Its principal place of  business is located at 1601 Cloverfield Blvd., Suite 5000N, Santa Monica, California 90404in Los Angeles County, State of California, and was so located during all pertinent timesreferred to herein. 5.Plaintiff is informed and believes that Defendant STRIKING DISTANCESTUDIOS, INC. (hereinafter “SDS”) is a California corporation with its principal place of  business located at 6111 Bollinger Canyon Road, Suite 150, San Ramon, California 94583in the Contra Costa County, State of California, and was so located during all pertinent timesreferred to herein.

2COMPLAINT FOR DAMAGES

 

123456789101112131415161718192021222324252627286.Plaintiff is informed and believes that Defendant KRAFTON VENTURESFUND, L.P. (hereinafter “KRAFTON FUND”) is a business entity, form unknown, and atall times mentioned herein, was and is authorized to do business in the State of California.Its principal place of business is located at 6111 Bollinger Canyon Road, Suite 150, SanRamon, California 94583 in the Contra Costa County, State of California, and was so locatedduring all pertinent times referred to herein. 7.Plaintiff is informed and believes that Defendant KRAFTON VENTURES,INC. (hereinafter “KRAFTON VENTURES”) is a business entity, form unknown, and at alltimes mentioned herein, was and is authorized to do business in the State of California. Its principal place of business is located at 6111 Bollinger Canyon Road, Suite 150, San Ramon,California 94583 in the Contra Costa County, State of California, and was so located duringall pertinent times referred to herein. 8.Plaintiff is informed and believes that Defendant KRAFTON VENTURES,L.L.C. (hereinafter “KRAFTON LLC”) is a business entity, form unknown, and at all timesmentioned herein, was and is authorized to do business in the State of California. Its principal place of business is located at 6111 Bollinger Canyon Road, Suite 150, San Ramon,California 94583 in the Contra Costa County, State of California, and was so located duringall pertinent times referred to herein. 9.Plaintiff is informed and believes that Defendant KRAFTON AMERICAS,INC. (hereinafter “KRAFTON AMERICAS”) is a business entity, form unknown, and at alltimes mentioned herein, was and is authorized to do business in Los Angeles County, in theState of California. Its principal place of business is located at 1601 Cloverfield Blvd., Suite5000N, Santa Monica, California 90404 in the Los Angeles County, State of California, andwas so located during all pertinent times referred to herein. 10.Plaintiff is informed and believes that the Defendants PUBG, PUBGENTERTAINMENT, KRAFTON, SDS, KRAFTON FUND, KRAFTON VENTURES,KRAFTON LLC and KRAFTON AMERICAS are all an alter ego of one another (collectively referred to herein as “Defendants”) and are all authorized to do business in the

3COMPLAINT FOR DAMAGES