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Robert V. Prongay (#270796) (rprongay@glancylaw.com) (info@glancylaw.com) Natalie S. Pang (#305886) GLANCY PRONGAY & MURRAY LLP 1925 Century Park East, Suite 2100 Los Angeles, California 90067 Telephone: (310) 201-9150 Michael A. Rose (MR@hachroselaw.com) Kathryn A. Hettler (KH@hrsclaw.com)

HACH ROSE SCHIRRIPA & CHEVERIE LLP 112 Madison Avenue, 10th Floor New York, New York 10016 Telephone: (212) 213-8311 Larry Nussbaum (larry@nlginjury.com) NUSSBAUM LAW GROUP P.C. 76 Canal Street, 4th Floor Boston, Massachusetts 02114 Telephone: (857) 245-9853

Counsel for Plaintiff

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

TIFFANY WELLS, Plaintiff, v. MELISSA V. JEFFERSON, Defendant.

Case No.: COMPLAINT FOR: 1)

Libel; 2)

Intentional Infliction of Emotional Distress; and 3)

False Light Invasion of Privacy JURY TRIAL DEMANDED

Case 2:19-cv-09808 Document 1 Filed 11/15/19 Page 1 of 13 Page ID #:1

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1 Plaintiff Tiffany Wells (“Plaintiff” or “Ms. Wells”), by and through her undersigned attorneys, complaining of Defendant Melissa V. Jefferson a/k/a Lizzo (“Defendant” or “Lizzo”), brings this action for libel, intentional infliction of emotional distress, and false light invasion of privacy. Upon information and belief, Plaintiff hereby alleges as follows:

I.

JURISDICTION AND VENUE

1.

This Court has diversity question jurisdiction under 28 U.S.C. § 1332 because the matter in controversy exceeds the sum or value of $75,000, and Plaintiff and Defendant are residents of different states. 2.

Venue is proper in this Court under 28 U.S.C. § 1391 because Defendant resides in this judicial district.

II.

PARTIES

Plaintiff

3.

Plaintiff Tiffany Wells is a 27-year-old female. Ms. Wells began working as courier for Postmates in approximately March 2019. Following the events described herein, Ms. Wells ceased working for Postmates on or about September 17, 2019. During all relevant times hereinafter mentioned, Ms. Wells was and still is a resident of the State of Massachusetts, County of Suffolk.

Defendant

4.

Defendant Melissa V. Jefferson, known professionally as “Lizzo,” is an American singer, songwriter, rapper, and actress. In 2019, Lizzo attained mainstream success with the release of her third studio album. To date, Lizzo has over one million followers on Twitter and approximately 5.5 million followers on Instagram. Lizzo is a resident of the State of California, County of Los Angeles.

III.

SUBSTANTIVE ALLEGATIONS

Plaintiff’s Background

5.

Upon graduating high school, Ms. Wells immediately joined the work force. From age eighteen until present day, Ms. Wells has held various customer


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2 service-related jobs. Indeed, Ms. Wells is a very perseverant and hard-working individual, at times, working three different jobs at once. Throughout her employment, Ms. Wells received various recognitions, including an award for quality of service. 6.

With regards to her employment, Ms. Wells amicably left each position she held. Either Ms. Wells left to seek a better opportunity, or her position was eliminated altogether. In fact, Ms. Wells began working as courier for Postmates in approximately March 2019 after she was laid off from her previous job. Following the events described herein, Ms. Wells ceased working for Postmates on or about September 17, 2019.

What is Postmates?

7.

Postmates is an American logistics company that works by connecting customers with couriers (i.e. a Postmate) who make deliveries for a huge variety of local businesses. Using the Postmates application (“app”), one can place an order for items ranging from food, alcohol, groceries, and more. A Postmate receives an order notification on their mobile device, then picks up the order and delivers it directly to the customer within minutes. 8.

When the Postmate arrives at the delivery address, the customer receives a notification of their arrival in their Postmates app and a push notification

1

is sent to the customer’s device. According to Postmates’ policies, if a Postmate is unable to locate the customer, or is having difficulties entering the customer’s building, the Postmate will call or text the customer at the number the customer provided at checkout.

2

A Postmate will wait at the delivery address and attempt to

1

A push notification is an automated message sent by an application to a user when

the application is not open.

2

Postmates.

What should I do if I missed my delivery?

https://support.postmates.com/buyer/articles/115002481648-article-What-should-I-do-if-I-missed-my-delivery- (last accessed September 27, 2019).
