||
LAW
OFFICES
OF
C.
RAY
CARLSON
C.
Ray
Carlson,
Esq.
SBN
93600)
2
||
Chad
R.
Carlson
Esq.
(SBN
289989)
3
||
27951
Smyth
Drive,
Suite
101
Valencia,
California
91355
4
||
Telephone:
(661)
294-0044
5
Facsimile:
661)
294-9475
Email:
chad
@craycarlson.com
6
Attorneys
for
Plaintiff
7
\|
BRYAN
M.
DELORENZO
8
9
SUPERIOR
COURT
OF
THE
STATE
OF
CALIFORNIA
10
FOR THE
COUNTY
OF
LOS
ANGELES
11
12
||
BRYAN
M.
DELORENZO,
Case
No.
13
Plaintiff,
COMPLAINT
FOR
NEGLIGENCE
14
VI
ys. 15
DEMAND
FOR
JURY
TRIAL
WARNER
BROS.
TELEVISION;
THE
CW
16 ||}
NETWORK;
DELTA
BLUES
PRODUCTIONS
LLC;
WARNER
HORIZON
SCRIPTED
\7
||
TELEVISION,
INC.;
SHOWALTER
1g
||
PRODUCTIONS,
INC.;
ROBBIE
THOMPSON;
JENSEN
ACKLES;
DANNEEL
ACKLES;
19
|}
DAVID
GOODMAN;
JOHN
SHOWALTER;
2
ALBERT
DICKERSON;
and
DOES
through
100,
inclusive,
21
Defendants.
22
23
24
25 26 27 28
COMPLAINT
I
Plaintiff
BRYAN
M.
DELORENZO
alleges
as
follows:
2
GENERAL ALLEGATIONS
3
1.
BRYAN
M.
DELORENZO
is
and
at all
relevant
times was,
an
adult
resident
citizen
of
4
||
the
County
of
Los
Angeles,
California.
5
2.
At
all
times
mentioned
herein,
Defendant
WARNER
BROS.
WORLDWIDE
6
||
TELEVISION DISTRIBUTION
INC.
“WARNER”)
was
and
is a
corporation
duly
organized
and
7
||
existing
under
the
laws
of
Delaware
with
its
principal
place
of
business
in
Los
Angeles,
County
8
||
California.
9
3. Plaintiff
is
informed
and believes, and
based thereon
alleges,
that
at all
times
mentioned
10
||
herein,
Defendant
THE
CW
NETWORK
LLC
was
and
is a
corporation
duly
organized
and
existing
11
||
under
the
laws
of
Delaware
with
its
principal
place
of
business
in
Los
Angeles,
County
California.
12
4,
Plaintiff
is
informed
and believes, and
based
thereon
alleges,
that
at
all
times
mentioned
13
||
herein,
Defendant
DELTA
BLUES
PRODUCTIONS
LLC
was
and
is a
limited
liability
company
duly
14
|| organized
and existing
under
the
laws
of
Louisiana
with
its
principal
place
of
business
in
Los
Angeles,
15
||
County
California.
16
5.
Plaintiff
is
informed
and believes, and
based
thereon
alleges,
that
at all
times
mentioned
17
||
herein,
Defendant
HORIZON
SCRIPTED
TELEVISION,
INC. was
and
is a
corporation
duly
organized
18
||
and existing
under
the
laws
of
Delaware
with
its
principal
place
of
business
in
Los
Angeles,
County
19
||
California.
20
6.
Plaintiff
is
informed
and believes, and
based
thereon
alleges,
that
at
all
times
mentioned
21
||
herein,
Defendant
SHOWALTER
PRODUCTIONS,
INC. was
and
is a
corporation
duly
organized
and
22
||
existing
under
the
laws
of
California
with
its
principal
place
of
business
in
Los
Angeles,
County
23
||
California.
24
7.
Plaintiff
is
informed
and believes, and
based
thereon
alleges,
that
at
all
times
mentioned
25
||
herein,
Defendant
ROBBIE
THOMPSON
is
and
at
all
relevant times
was,
an
adult
resident
citizen
of
26
||
the
County
of
Los
Angeles,
California.
27 28
2
COMPLAINT
8.
Plaintiff
is
informed
and believes and
based thereon
alleges
that
at
all
times
mentioned
2
||
herein
Defendant
JENSEN
CKLES
is
and
at
all
relevant
times was
an
adult
resident
citizen
of
the
3
}|
ounty
of
Los
Angeles
California.
4
9.
Plaintiff
is
informed
and believes and
based thereon
alleges
that
at all
times
mentioned
5
||
herein
Defendant
D NNEEL
CKLES
is
and
at
all
relevant
times was
an
adult
resident
citizen
of
the
||
County
of
Los
Angeles
California.
7
10
Plaintiff
is
informed
and believes and
based thereon
alleges
that
at
all
times
mentioned
8
||
herein
Defendant
D VID
GOODM N
is
and
at all
relevant
times was
an
adult
resident
citizen
of
the
9
||
County
of
Los
Angeles
California.
10
11
Plaintiff
is
informed
and believes and
based
thereon
alleges
that
at
all
times
mentioned
11
||
herein
Defendant
JOHN
SHOW LTER
is
and
at all
relevant
times was
an
adult
resident
citizen
of
the
12
||
ounty
of
Los
Angeles
California.
13
12
Plaintiff
s
informed
and believes and
based
thereon
alleges
that
at all
times
mentioned
14
||
herein
Defendant
LBERT
DICKERSON
is
and
at all
relevant
times was
an
adult
resident
citizen
of
15
||
the
County
of
Los
Angeles
California.
16 13
DOES
to
100
inclusive
are
sued
herein
under
such
fictitious
names
their
true
names
17
||
and capacities
being presently
unknown
to
Plaintiff.
Plaintiff
will
seek leave
of this
Court
to
amend
the
18
||
complaint
by
asserting
the true
names
and capacities
of
the
additional
Defendants
in
place
of
the
19
||
fictitious
names
when
Plaintiff
ascertains
the
true
names.
20
14
Plaintiff
is
informed
and believes and
based
thereon
alleges
that
each
Defendant
21
||
designated
herein
as
DOES
|
to
100
inclusive
is
responsible
in
some
m nner
for the acts
or
22
||
occurrences
alleged
herein
whether
such
acts
or
occurrences
were
committed
intentionally
negligently
23
||
recklessly
or
otherwise
and
that
each
DOE
Defendant
s
liable
to
Plaintiff
for
damages
suffered
by 24
||
Plaintiff
as
alleged
herein.
25
15
Plaintiff
s
informed
and believes and
based
thereon
alleges
that
at all
times
mentioned
26
||
here
each
of
the
Defendants
was
the
agent
employee
designee
servant
authorized
representative
27
|| partner
joint
venturer
co-conspirator
and
alter
ego
of
each
of
the
remaining Defendants
and
was
in
28
||
doing
the
things
complained
of
here
acting
within
the
purpose
and
scope
of
such
agency
employment
3
COMPL INT