18 19 20 David M. Ring (State Bar No. 151124) CONFORMED COPY Brendan Gilbert (State Bar No. 274631) ORIGINAL FE Fromme TAYLOR & RING Super Oot nes 10900 Wilshire Boulevard, Suite 920 + 93.2018 Los Angeles, California 90024 DEC 032 Telephone: (310) 209-4100 rei Gato, tna eno Sy ul Lar Attorneys for Plaintiff, ay SCOTTINE ROSS SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES casero: BOS 03155 SCOTTINE ROSS, an individual, Plaintiff, COMPLAINT FOR PERSONAL INJURIES AND DAMAGES: ~vs- 1, ASSAULT CHARLIE SHEEN, an individual, and BATTERY DOES 1 through 20; inclusive, 3. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS Defendants, 4, FALSE IMPRISONMENT 5. NEGLIGENCE (DEMAND FOR JURY TRIAL) p Plaintiff SCOTTINE ROSS complains and alleges against Defendants CHARLIE SHEEN and DOES 1 through 20 as follows: GENER. 1. Plaintiff SCOTTINE ROSS (‘Plaintiff’) is, and at all times herein mentioned was, a resident of the County of Los Angeles, State of California, In late 2013, Plaintiff was 24 years old. She was working as an adult film actress. COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 11 12 13 14 15 16 a7 18 19 20 21 22 23 24 2, Defendant CHARLIE SHEEN (“SHEEN”) is, and at all times herein mentioned was, a resident of the County of Los Angeles, State of California, At the time he first met Plaintiff in late 2013, he was 48 years old and was a famous actor. 3. Turisdiction and venue are proper in the Superior Court of Los Angeles County because it is where the incidents occurred and where Defendant SHEEN resides. 4, The true names and capacities of Defendants DOES 1 through 20, whether an individual, business, or some other entity, are presently unknown to Plaintiff who therefore sues said Defendants by such fictitious names pursuant to Code of Civil Procedure section 474, When the true names, identities or capacities of such fititfously designated Defendants are ascertained, Plaintiff will ask leave of Court to amend the complaint fo assert the true names, identities and capacities, together ‘with the proper charging allegations, 5. Each of the Defendants designated herein as a DOE was the agent and employee of each of the remaining defendants and was at all times acting within the course and scope of such agency and employment with the full knowledge, consent, authority, ratification and/or permission of each of the remaining defendants, 6. Wherever appearing in this complaint, each and every reference to Defendants, ot any of them, is intended to include, and shall be deemed to include, all ficttiously named defendants, FACTS COMMON TO ALL CAUSES OF ACTION Plaintiff's Basis for Filing this Lawsuit in the Superior Court 7. Beginning in early in 2015 Plaintiff, acting through counsel, attempted to resolve the valid claims set forth herein with SHEEN. After first attempting to force Plaintiff to submit to a binding confidential arbitration proceeding pursuant to an illegal, invalid and void non-disclosure agreement ("NDA"), and after much delay, in late October and early November 2015, SHEEN agreed COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 11 12 13 14 15 16 Md 18 19 20 21 22 23 24 in prineipal to resolve Plaintif?'s claims against him for the sum of $1 million to be paid on December 2, 2015, and to assign to her five percent of his 100 percent back end participation (namely, the "modified adjusted gross") in the TV series Anger Management. In exchange, Plaintiff agreed in principal to accept the settlement and to enter info an agreement that, among other things, required her to release any and all claims she had against SHEEN. 8. Plaintiff'in fact entered into the written agreement that was prepared by SHEEN'S representatives. SHEEN then refused to enter into that same agreement, which his representatives had prepared, claiming that Plaintiff had somehow "breached" the agreement (which SHEEN never signed) and then demanding that Plaintiff submit to confidential binding arbitration in order to resolve the "alleged" dispute about the alleged "breach." 9. This scheme by SHEEN to renege on the agreement that was reached in principal and to then attempt to force Plaintiff to arbitrate the "dispute" in a confidential forum came on the heels of SHEEN appearing on The Today Show on NBC on November 17, 2015 and declaring that he was HIV-positive and that he had no intention whatsoever to honor any previous settlement agreements he had entered into with any females who had brought claims against SHEEN based on his engaging in sex with them while knowing he was HIV positive. 10. SHEEN'S ploy regarding Plaintiff was to induce her to sign a settlement agreement before SHEEN ever signed it, then claim that Plaintiff "breached" the "draft" settlement agreement, and then demand that Plaintiff resolve the "dispute" in a confidential setting, per the terms of the agreement (which, again, SHEEN never signed.) 11, Plaintiff did not breach any "draft" agreement, Plaintiff at all times honored her end of the agreement, Regardless, SHEEN never formally entered into the written agreement despite COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 11 12 ig) 14 15 16 17 18 19 20 21 22 23 24 agreeing to the deal in principal and having his representatives prepare the final agreement. As such, there is no agreement between SHEEN and Plaintiff. 12, Plaintiff now brings her claims in the Superior Court of the State of California, as she is entitled to do, because there exists no valid or binding agreement between Plaintiff and SHEEN that requires her to submit to # confidential tribunal to resolve any dispute she has with him. Sheen’s Physical, Psychological, and Emotional Abuse of Plaintiff 13, In the late evening on November 1, 2013, Plaintiff arrived at SHEEN’s residence for the sole purpose of engaging in sexual intercourse with SHEEN for monetary compensation, Plaintiff had never met SHEEN prior to this night. However, SHEEN had repeatedly asked one of Plaintiffs friends for an introduction, and ultimately told the friend he wanted to have sex with Plaintiff because hhe had seen her on a website. He then told Plaintiff's friend he would pay $10,000 to PlaintifFif she came over to his house and had sex with him, Plaintiff ultimately agreed to do so. After arriving at the residence, but prior to meeting SHEEN, Plaintiff was forced into signing an illegal and unenforceable non-disclosure agreement (“NDA”) by an associate of SHEEN. The signing of the NDA occurred as a direct result of coercion, undue influence, duress, oppression and/or fraud 14, The sole object for having Plaintiff sign the NDA before she entered SHEEN'S home ‘was to facilitate the illegal act of Plaintiff engaging in sexual intercourse with SHEEN in exchange for monetary compensation. As such, the NDA is and was an illegal contract, one that is not recognized or enforced by law. The NDA cannot be enforced, as it is and was illegal, null and void, One cannot center into a contact the sole purpose of which is to engage in illegal activities, Plaintiff acknowledges that her sole purpose for going to SHEEN'S home on November 1, 2013 was to engage in sex with him in exchange for a monetary payment. COMPLAINT FOR PERSONAL INJURIES AND DAMAGES.10 al 12 13 14 15 16 17 18 19 20 21 22 23 24 15, After Plaintiff signed the NDA and entered Sheen's residence, SHEEN provided Plaintiff with an envelope containing $10,000 in cash and, in the early morning of November 2, 2013, SHEEN and Plaintiff engaged in sexual intercourse. Plaintiff had no expectation of ever seeing SHEEN again. However, over the course of the evening, the two hit it off and both wanted to continue spending time together, and did in fact spend alot of time together thereafter. 16. Within weeks, Plaintiff fell in love with SHEEN and believed SHEEN fell in love with her, They became romantically involved. They became a couple and spent most of their time together. They discussed a long-term relationship and both desired a serious relationship with the other and to be exclusive with each other and not date or see anyone else. 17. _ SHEEN convinced Plaintiff to quit nursing school by assuring her that they would eventually be getting married and that he would be “taking care of he:” for the remainder of her life because of how strongly he felt about her. 18. Plaintiff and SHEEN began doing everything together as a couple, SHEEN told Plaintiff that he was no longer drinking in excess or doing drugs, and Plaintiff believed him and did not personally witness any such behavior in the first few weeks they were together, 19, However, Plaintiff soon discovered that SHEEN would drink in excess and that he ‘became a different person when he did so. He became violent and abusive and uncontrollable toward Plaintiff and others, When sober, SHEEN was someone Plaintiff loved and wanted to be with. But on those occasions when SHEEN drank alcohol or used drugs, he became a different person than the one Plaintiff had fallen in love with, 20. In November of 2013, around Thanksgiving, while Plaintiff and SHEEN were ‘vacationing in Cabo San Lucas, Mexico, Plaintiff observed SHEEN yelling and punching a hole in the COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 1 12 13 14 15 16 a7 18 19 20 21 22 23 24 wall of their hotel suite while she was in bed, SHEEN then aggressively dragged Plaintiff out of bed by her arms and began violently shaking her while screaming obscenities at her. 21, In December of 2013, SHEEN would regularly scream obscenities at Plaintiff, back her into comers, push her onto the floor, and drag her by her arms, On one oceasion, SHEEN locked Plaintiff in the bathroom with him while he interrogated her about how many men she had been with, proclaiming that he would not let her leave until she answered his questions. 22. During the last two weeks of December 2013, SHEEN became enraged when Plaintiff ‘would not accept gifts from him. Specifically, SHEEN screamed at her, pushed her, cornered her, broke items in and around their home, threw items from theit bedroom out the balcony window and into the pool, and shook her until she agreed to accept his gifts. 23. Inlate December 2013, while Plaintiff and SHEEN were vacationing in Punta Mita, Mexico, Plaintiff decided to stay in a separate room from SHEEN during the first night of their trip after he had become extremely intoxicated. The next moming, Plaintiff woke up to a barrage of insulting and demeaning text messages from SHEEN, stating that Plaintiff was an “ungrateful bitch” for staying in another room, 24, On January 1, 2014, Plaintiff and SHEEN decided to fly to Iceland from Mexico. During this flight, SHEEN attempted to feed french fries to Plaintiff, who said that she didn’t want any. SHEEN then burst into a fit of rage, throwing the french fries across the plane. SHEEN began screaming obscenities at Plaintiff, telling her that she was an “ungrateful bitch.” SHEEN then geabbed his iPed, threw it to the ground, and began stomping on it in front of Plaintiff, 25. After all of these outbursts, once sober, SHEEN would profusely apologize to Plaintiff and tell her he wanted to stop drinking and that she was incredibly important to him and he did not. COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 41 12 13 14 15 16 17 18 19 20 21 22 23 24 want the relationship to end. He would convince her that he was making a concerted effort to get his life in order and that he wanted her to be his wife and that he was in love with her. 26. In the early stages of their relationship, Plaintiff and SHEEN had sexual intercourse on at least five occasions before Plaintiff discovered medication in SHEEN’s medicine cabinet (Truvada”) that was for the treatment of HIV, Shorily after this discovery, SHEEN admitted to Plaintiff that he was HIV-Positive. Plaintiff told SHEEN that he should have disclosed this to her before they ever engaged in any sex. If SHEEN had disclosed to Plaintiff that he was HIV positive ‘when they met for the very first time, Plaintiff would never have engaged in sex with him, and the resulting relationship between the two would never have occurred. 27. Plaintiff and SHEEN then had a “heart to heart” talk where SHEEN expressed how much her cared about and loved her, and that he was committed to staying with her for the long term. After SHEEN convinced Plaintiff that he was devoted to her, that she was the one for him, and that he /was ready to Settle down with her, Plaintiff agreed to stay in a relationship with SHEEN despite the fact that he was HIV-Positive. As a result, Plaintiff researched medication that would help prevent the ‘transmission of HIV from SHEEN to her, because they agreed that since they were going to be together for the long term, that they would engage in unprotected sexual intercourse like a normal couple. 28, On January 3, 2014, SHEEN asked Plaintifi'to marry him. SHEEN suggested they go ‘to Vegas so that they could get matried right away, Plaintiff, who was in the midst of finalizing her divorce ftom her first husband, told SHEEN that she wanted to marry him also but that, of course, she needed her divorce finalized first, 29. On or around January 20, 2014, SHEEN began to interrogate Plaintiff about her ex- husband, SHEEN demanded that Plaintiff give him her ex-husband's phone number. When Plaintiff COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 a 12 13 14 15 16 17 18 19 20 21 22 23 24 refused, SHEEN became enraged and began screaming obscenities at her. SHEEN then flipped a coffee table over in Plaintiff's direction, narrowly missing her. SHEEN then pushed Plaintiff into a corner, continuing to scream at her. It was at this point that SHEEN took a swing at Plaintiff, attempting to punch her, which was witnessed by multiple individuals, He did not make contact with Plaintiff. In shock, Plaintiff curled into ball on the ground and began crying hysterically. SHEEN then began kicking Plaintiff while she was down on the ground, 30. During January 2014, SHEEN admitted to Plaintiff that he had relapsed on crack cocaine, SHEEN told Plaintiff that he had used crack cocaine at least three times that month, He begged for forgiveness and told Plaintffhe stil wanted to marry her and that he wes going to make serious efforts to get his life under control and that he desperately wanted to get sober. 31. SHEEN’s violent outbursts would typically be followed by days or weeks of sober Joehavior. He would be loving and charming and sweet to Plaintiff. He would beg forgiveness for "a bad night” or a violent outburst. But, a patter was emerging: just as everything seemed fine and stable, SHEEN would once again drink or use drugs and often on those occasions he would tum violent or abusive towards Plaintiff 32. In January 2014, SHEEN described to Plaintiff, in graphic detail, about how he wanted to murder people that he was angry with. Plaintiff would frequently ask him to stop this, as it made her very uncomfortable. 33. At some point in January 2014, SHEEN told Plaintiff that he wanted to put a “hit” on Plaintiff's ex-husband, Plaintiff dismissed SHEEN’s comments as ridiculous, but he persisted with these comments to the point where Plaintiff began to believe he was serious, When Plaintiff pleaded with SHEEN stop talking about it, SHEEN became enraged. One evening, Plaintiff discovered text messages on SHEEN’s phone indicating that some sort of “hit” had indeed been placed on her ex- COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 1 12 13 14 15 16 a7 18 19 20 21 22 23 24 husband. When Plaintiff confronted SHEEN, SHEEN locked Plaintiff in a room for hours, screaming at her and telling her that she was “fucking stupid” for involving herself in the matter. SHEEN also told Plaintiff if the “hit” was ever traced back to him that he would tell the police that Plaintiff was the ‘one who ordered it, that it was entirely her plan, and that he would use his money and influence to make sure that she ended up going to prison for it, 34. A few weeks later, Plaintiff's ex-husband sent her a screen shot of one of his home security cameras, depicting a suspicious unknown man wearing a hooded jacket knocking on his front door very late at night. 35. In February 2014, Plaintiff and SHEEN went on a trip to Hawaii, While on a private boat with some friends, SHEEN became enraged at Plaintiff and started screaming at her, and threw his drink in her face. SHEEN called Plaintiff a “piece of shit,” and threw the Tiffany bracelet that she had given to him as a gift into the ocean, Plaintiff hid in a bathroom on the boat because she was fearful for her life given SHEEN’s outrageous actions. Once docked, Plaintiff walked by SHEEN to get off the boat, and he hissed at her and then said “fucking bitch!” SHEEN’s security then forced Plaintiff to get into the same vehicle as him, with her seated in the back seat and him in the front seat, SHEEN then turned around, attempted to strike Plaintiff and spit in her face. Fearing for her safety, Plaintiff exited the vehicle and then ran to vehicle being driven by an associale of SHEEN’s, demanding that he lock the doors once she got in because she feared for her safety. SHEEN then approached the SUV and began beating on the window of the SUV, demanding Plaintiff to get out of the vehicle and fight him. SHEEN continued punching the window and spitting on it, yelling that he ‘was going to beat Plaintiff's “fucking ass” and that he was going to kill her. 36. In March 2014, Plaintiff discovered that she was pregnant with SHEEN’s child, Plaintiff was happy about this, as she and SHEEN had frequently discussed having a child that they COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 ey 12 13 14 15 16 ay 18 19 20 21 22 23 24 could raise together. SHEEN even told Plaintiff that if she conceived a girl, that he wanted to name ‘ner “Charlie.” But when Plaintiff told SHEEN that she was pregnant, he became extremely upset. SHEEN indicated that he did not want his child to have his blood type (i.e., HIV-Positive). SHEEN told Plaintiff that she had to have an abortion. When Plaintiff told SHEEN that she did not want to have an abortion, SHEEN erupted into a fit of rage, stating he would “kick her to the curb” if she did not have an abortion, and that he did not want her “to give birth to a retarded child.” Aer much pressure and threats, Plaintiff had the abortion, 37. On Easter Sunday in 2014, SHEEN become enraged at Plaintiff when she took a bottle of vodka away from him after observing him drinking straight ftom it, As result, SHEEN began breaking and destroying things in their backyard, SHEEN’s security personnel advised Plaintiff that, for her own safety, she should go indoors. Once inside, Plaintiff watched SHEEN from behind the glass doors leading to the backyard. When SHEEN saw Plaintiff observing him throwing his tantrum, he picked up a cement pillar and threw it in her direction, ‘The pillar struck and broke the glass doors that Plaintiff was standing behind. It was clear to Plaintiff that SHEEN threw the pillar intending for it to strike her. 38. In May 2014, SHEEN again lost his temper and became irrational with Plaintiff. SHEEN accused Plaintiff of trying to hit him, Plaintiff had not tried to hit him. SHEEN then grabbed Plaintiff by her neck, and pushed her into the wall. SHEEN screamed at her “Don’t you ever fucking hitme, I'll fucking kill you.” SHEEN then slammed Plaintiff on the floor, and put her in a choke hold. Plaintiff began screaming and crying that she could not breathe, but SHEEN just kept repeating that if she ever tried to hit him again, he would kill her. SHEEN finally released Plaintiff from the choke hold that he had her in just as she was starting to black out, 10 COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 aa 12 13 14 15 16 17 18 19 20 21 22 23 24 39. In June 2014, during a car ride home from SHEEN’s eldest daughter’s house, SHEEN pulled out a gun that he regularly kept in his vehicle. Knowing that SHEEN was intoxicated, Plaintiff asked if SHEEN would put the gun away, stating that guns made her nervous, SHEEN then began pointing the (unloaded) gun at her and repeatedly pulling the trigger. Plaintiff began crying, begging hhim to stop but he continued to point it at her and pull the trigger. After asking again that he put the gun away, SHEEN, in a fit of rage, threw his DuPont white gold lighter at the rearview mirror of the vehicle, causing it to shatter and glass to fly everywhere, including into the eyes of the security personnel driving the vehicle, 40. Between July and September 2014, SHEEN continued his pattern of emotional abuse of Plaintiff. But, after each outburst, SHEEN would beg forgiveness, tell Plaintiff he loved her, that she ‘was the only one for him, that he wanted to marry her, and that he was trying to get his life under control. That would be followed by days or weeks of peaceful, calm and loving behavior by SHEEN towards Plaintiff. Plaintiff admits, in hindsight, that she was in denial about the extent of SHEEN's issues and the toil it was taking on the relationship, She wanted to be with him and was in love with hhim and tried to justify the relationship by believing that if SHEEN could stay sober than everything would be fine. Again, Plaintiff was 24 years old at the time of this relationship, 41, Between July and September 2014, SHEEN became increasingly less diligent and responsible in taking his HIV medication as a result of his illegal drug use. This was typical, as ‘whenever SHEEN’s illegal drug use would get out of control, he would routinely fail to take his HIV ‘medication. Plaintiff would ask SHEEN if he was taking the medication, and he would convince her he was, but then she would determine later that, in fact, he was not taking it at certain times. This was very conceming to Plaintiff, as he put her at a substantial risk of contracting HIV by not taking his medication. uw COMPLAINT FOR PERSONAL INJURIES AND DAMAGES.10 11 12 13 14 1s 16 17 18 19 20 21 22 23 24 42, In September 2014, Plaintiff and SHEEN were engaged in sexual intercourse when SHEEN starting acting very aggressively and violently. SHEEN also started to act belligerent by rambling and saying things that didn’t make sense, As SHEEN started getting mote and more violent during the intercourse, Plaintiff asked him stop and told him that he was hurting her, The pain got so bad that Plaintiff began crying and begging SHEEN to stop. When it was finally over, Plaintiff ran to the bathroom and noticed that she was bleeding because of a tear caused by SHEEN. As usual, SHEEN apologized for this behavior and promised it would never happen again, 43. Without waming, in October 2014, SHEEN ended his relationship with Plaintiff via text message. Plaintiff was devastated because she believed that, despite all they had been through, she and SHEEN had a very serious relationship. This belief was supported by the fact that SHEEN asked Plaintiff to publicly change her name to “Scottine Sheen,” which she had done. SHEEN told Plaintiff he wanted her to share his last name now, even if they had to wait to get married, This was also evidenced by the fact that Plaintiff and SHEEN adopted a flamingo at the Santa Barbara Zoo ‘which had a permanent plaque (approved by SHEEN) associated with it that read “Klay-vinn; sponsored by Charlie and Scottine Sheen.” Additionally, Plaintiff spent substantial amounts of time with SHEEN’s children from prior marriages, frequently keeping them company and watching over them when they would come over to visit. Plaintiff would also visit these children at SHEEN’s ex- wife’s home. Moreover, SHEEN gave permission to his family law attorneys to discuss with Plaintiff his ongoing custody battles and, frequently, she would be the sole person to discuss these issues with these attorneys on SHEEN’s behalf. In addition to family matters, SHEEN and Plaintiff also engaged extensively in private business matters, regularly making business decisions together. 44, Asa result of the physical, psychological, and emotional torment that she had been subjected to, and then to have SHEEN abruptly end the relationship with her without explanation, 2 COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 1 12 13 14 158 16 17 18 19 20 21 22 23 24 Plaintiff went into an emotional tailspin and became extremely depressed and ultimately attempted to commit suicide, After surviving this attempt, Plaintiff received a text message from SHEEN stating “(funny how an ex-nursing student couldn’t calculate the appropriate dosage of a vintage drug such as valium to successfully kill herself.” After this, SHEEN would regularly send insulting and demeaning text messages to Plaintiff, 45. In December 2014, Plaintiff attempted to commit suicide a second time because she feared that SHEEN would continue to emotionally abuse her both privately and publiely, and she could not deal with the emotional distress anymore. 46, Barly in their relationship, SHEEN gave Plaintiff a Mercedes Benz vehicle as a gift and, after their break, SHEEN never requested that she return it, But in March 2015, without any notice, Plaintiff woke up one morning and discovered that someone had come onto her private property and took the Mercedes. This caused Plaintiff significant distress, knowing that SHEEN had likely hired someone to trespass onto her property in the middle of the night to get the car. This also caused Plaintiff distress because, through her relationship with SHEEN, she became awate of individuals that SHEEN would hire, many of whom were violent and had gang affiliations, to harass and intimidate people. As a result, Plaintiffno longer feels safe at her home and fears for her safety. 47. Plaintiff has struggled with her emotions since the relationship ended and is currently taking medication, as well as seeing health care professionals as a result. Plaintiff was truly in love with SHEEN, She truly believed they had something special together. She truly believed that SHEEN was in love with her and wanted to marry her. She also believed if SHEEN had stayed sober than everything would be fine. But SHEEN could not stay sober. And when he was drinking or using drugs, he often would target her with abusive conduct, She did nothing to provoke it. She blindly stayed in the relationship until SHEEN ended it via text message, Months later, she realized how 1B COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 11 12 13 14 15 16 ) 18 19 20 21 22 23 24 ‘harmful the relationship was to her emotional state. She admits she was the classic "eo-dependent" gitlftiend, who "accepted" the verbal and physical abuse in an effort to save the relationship. But she now realizes that SHEEN likely had no intention of ever marrying her or staying with her. Instead, part of the entire ruse was to get her to fall in love with him, convince her that they would be together forever, and that, in tum, allowed Plaintiff to be manipulated into agreeing to engage in unprotected sexual intercourse with SHEEN, despite knowing he was HIV-positive. RST CAUSE OF ACTION ASSAULT (On Behalf of Plaintiff and Against Defendant SHEEN and DOES 1-20) 48. Plaintiff re-alleges and incorporated herein by reference each and every allegation contained in paragraph 1 through 47, 49. As described above, SHEEN on numerous occasions committed overt acts with the intent to either inflict a harmful or offensive touching or cause Plaintiff to fear such contact. These acts include but are not limited to being kicked while on the ground, being choked to the point of almost losing consciousness, being dragged around by her arms, being violently shaken, having a large pillar thrown at her, and having a gun pointed at her and the trigger being pulled. 50. SHEEN knew, or should have known, that his overt acts were substantially certain to result in Plaintiff fearing of immediate harmful or offensive contact. In response to these overt acts, Plaintiff had a reasonable apprehension of immediate harmful or offensive contact. Plaintiff did not consent to these overt acts, these acts were a substantial factor in bringing about harm to Plaintiff, and Plaintiff suffered actual harm as a result, 51. Asa direct and legal result of SHEEN’s misconduct, Plaintiff suffered injuries including, but not limited to, physical injuries, mental pain and suffering, emotional distress, past and 4 COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 ql 12 13 14 15 16 a 18 19 20 21 22 23 24 future costs of medical care and treatment, and other economic and non-economic damages in an amount not yet ascertained, but which exceed the minimum ju lictional limits of this Court. 52, In committing the acts described herein, SHEEN acted with willfulness, malice, and oppression, justifying an award of punitive damages against him. SECOND CAUSE OF ACTION BATTERY (On Behalf of Plaintiff and Against Defendant SHEEN and DOES 1-20) 53. Plaintiff're-alleges and incorporated herein by reference each and every allegation contained in paragraph 1 through 52. 54, As described above, SHEEN on numerous occasions harmfully or offensively physically contacted Plaintiff's person (or caused Plaintif?’s person to be contacted). This conduct included but was not limited to being kicked while on the ground, choked to the point of almost losing consciousness, being dragged around by her arms, and being violently shaken, On all of these offensive occasions, Plaintiff did not consent to the harmful or offensive contact, As a result of these harmful or offensive contacts by SHEEN, Plaintiff was in fact harmed or offended. 55, — Onone occasion, as described above, SHEEN engaged in violent and aggressive sexual intercourse with Plaintiff after Plaintiff instructed him several times to "stop" because he was physically hurting her. SHEEN refused to stop. SHEEN committed a sexual battery upon Plaintiff. 56. When Plaintiff first met SHEEN, he never disclosed to her that he was HIV positive. Plaintiff engaged in sex with SHEEN approximately five times before learning he was HIV positive. Each of those acts constituted a sexual battery by SHEEN. Had Plaintiff been told that SHEEN was HIV positive, she would never have consented to engage in sexual intercourse with him, When she did learn of his condition, she was already in love with him, and willing to do anything for him and for 15 COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 a 12 13 a4 15 16 17 18 19 20 21 22 23 24 the relationship, which is why she then agreed to staying in the relationship and continuing to engage in sex with him, 57. Asa direct and legal result of SHEEN’s misconduct, Plaintiff suffered injuries including, but not limited to, physical injuries, mental pain and suffering, emotional distress, past and future costs of medical care and treatment, and other economic and non-economic damages in an amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court. 58. In committing the acts described herein, SHEEN acted with willfulness, malice, and oppression, justifying an award of punitive damages against him, THIRD CAUSE OF ACTION INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (On Behalf of Plaintiff Against Defendant SHEEN and DOES 1-20) 59, Plaintiff re-alleges and incorporates herein by reference cach and every allegation contained in paragraphs 1 through 58 60. As described above, SHEEN on numerous occasions exhibited extreme and outrageous conduct directed towards Plaintiff that was beyond all bounds of decency tolerated by society. This conduct included but was not limited to being kicked while on the ground, being choked to the point of almost losing consciousness, threats of harm, and psychological and verbal abuse, This conduct was done with the intention to cause, or with reckless disregard of the probability of causing, Plaintiff to suffer severe emotional distress. As a result, Plaintiff suffered severe and enduring emotional distress which was actually and proximately caused by SHEEN’s extreme and outrageous conduct. 61. SHEEN’s outrageous conduct also included his exposure of Plaintiff to HIV by engaging in sexual intercourse with her, knowing that he was HIV-positive, By doing so, SHEEN intended to cause Plaintiff emotional distress or acted with a reckless disregard of the probability that 16 COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 4. 12 13 14 45 16 aa 18 19 20 21 22 23 24 Plaintiff would suffer emotional distress. As a result, Plaintiff suffered severe emotional distress from a reasonable fear of contracting HIV, and SHEEN was a substantial factor in causing Plaintiff's emotional distress. 62. Asa direct and legal result of SHEEN’s misconduct, Plaintiff suffered injuries including, but not limited to, physical injuries, mental pain and suffering, emotional distress, past and future costs of medical care and treatment, and other economic and non-economic damages in an amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court 63. In committing the acts described herein, Defendant SHEEN and DOES 1-20 acted with willfulness, malice, and oppression, justifying an award of punitive damages. FOURTH CAUSE OF ACTION FALSE IMPRISONMENT (On Behalf of Plaintiff Against Defendant SHEEN and DOES 1-20) 64, _ Plaintiff're-alleges and incorporates herein by reference each and every allegation, contained in paragraphs 1 through 63, 65. As described above, SHEEN on numerous occasions intentionally exercised force, or threat of force, to restrain, detain and confine Plaintiff, depriving Plaintiff of her liberty and compelling her to stay where did not want to remain, This includes but is not limited to when SHEEN locked Plaintiff in the bathroom for hours while interrogating her, and refused to let her leave, as well as when he choked her to the point of almost losing consciousness. On each of these occasions: 1) Plaintiff was detained, restrained and confined for an appreciable length of time; 2) SHEEN intended to detain, restrain and confine Plaintiff, 3) Plaintiff did not consent to the detention, restraint and confinement; and 4) Plaintiff was in fact harmed as a direct result of the detention, restraint and confinement. uv COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 1 12 13 4 15 16 aw 18 19 20 21 22 23 24 66, Asadirect and legal result of SHEEN’s misconduct, Plaintiff suffered injuries including, but not limited to, physical injuries, mental pain and suffering, emotional distress, past and future costs of medical care and treatment, and other economic and non-economic damages in an amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court. 67. In committing the acts described herein, SHEEN acted with willfulness, malice, and oppression, justifying an award of punitive damages against him, FIFTH CAUSE OF ACTION NEGLIGENCE (On Behalf of Plaintiff Against Defendant SHEEN and DOES 1-20) 68. Plaintifi're-alleges and iricorporates herein by reference each and every allegation contained in paragraphs 1 through 67. 69. As described above, SHEEN engaged in sexual intercourse with Plaintiff on at least five separate occasions without disclosing to her that he wes HIV-Positive. SHEEN had a duty to disclose to Plaintiff that he was HIV-Positive prior to engaging in sexual intercourse with her when he first met her in November 2013. Further, SHEEN promised to take the medication designed to prevent the spread of HIV during their relationship, yet did not abide by that promise, thus farther exposing Plaintiff to harm. By failing to make these disclosures, SHEEN breached his duty of care. SHEEN's breach of this duty caused Plaintiff to suffer harm, 70. Due to SHEEN’s negligent failure to disclose to Plaintiff that he was HIV-Positive, Plaintiff was exposed to HIV. As a result of this exposure, Plaintiff has suffered serious emotional distress from a reasonable fear that she will contract HIV. 71, Asa direct and legal result of this conduct, Plaintiff suffered injuries in an amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court. 18 COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 qi 12 13 14 15 16 47 18 19 20 21 22 23 24 72, In.committing the acts described herein, SHEEN acted with willfulness, malice, and oppression, justifying an award of punitive damages. PRAYER FOR RELIEE WHEREFORE, Plaintiff SCOTTINE ROSS prays for judgment against Defendant CHARLIE SHEEN as follows: 1, For an award of special (economic) and general (non-economic) damages according to pro 2. For punitive damages against CHARLIE SHEEN; 3. For costs of suit incurred herein; 4, For such other and further relief as the Court deems just and proper. Dated: December 3, 2015 TAYLOR & RING By _ Le Zz Cpe David M. Ring Attorneys for Plainti SCOTTINE ROSS 19 COMPLAINT FOR PERSONAL INJURIES AND DAMAGES10 cht 12 13 14 15 16 a) 18 19 20 21 22 23 24 trial by jury. Dated: December 3, 2015 By: 20 Plaintiff hereby demands that her action for personal injuri DEMAND FOR JURY TRIAL and damages be determined by TAYLOR & RING David M. Ring Attorneys for Plaintiff, SCOTTINE ROSS COMPLAINT FOR PERSONAL INJURIES AND DAMAGES