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COPY 0 a n a 2 nny 28 SS | Sitlow inch carne fieeAr ue Bryon M Sliven, Sate Bar Number 209743 a ‘eullvan@earysullvancom “ONG EARLY SULLIVAN WRIGHT Guzen MeRAL “LP gory (6420 Wilshire Boulevard, 17% Floor EC 04 2017 [Los Angeles, Califorria 90048 : ‘Telephone: (323) 301-4660 es uc case dC Facsimile: (323) 301-4676 Marlon Gomes, Depuiy ‘Attorneys for Plaintif TERRY CREWS SUPERIOR COURT OF THE STATE OF CALIFORNIA, FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT i BC685719 TERRY CREWS, i individual, case No. Plait, COMPLAINT FOR DAMAGES FOR: (1) ASSAULT * @ barteRy Q) SEXUAL BATTERY, ADAM VENIT, anindividual, WILLIAM | (CAL.CLV.CODE §1708.5) ‘MORRIS ENDEAVOR (8) SEXUAL HARASSMENT ENTERTAINMENT, LLC, aDelaware | (CAL.CIV.CODE §51.9) limited liability company, and DOES | thra | (3) GENDER VIOLENCE 25; (CAL.CIV.CODE §82.4) (@ INTENTIONAL INFLICTION OF Defendants EMOTIONAL DISTRESS (7) BREACH OF FIDUCIARY DUTY (8) NEGLIGENCE. (0) NEGLIGENT RETENTION AND SUPERVISION DEMAND FOR JURY TRIAL COMPLAINT Fa n a By 2s 26 n gaa 28 ES | sits = ime GM | EAP ue PLAINTIFF TERRY CREWS (“Crews”) complains and alleges the following against DEFENDANTS ADAM VENIT (“Vent”), and his employer, WILLIAM MORRIS ENDEAVOR, ENTERTAINMENT, LLC (“WME”), and DOES 1 thru 25 (all defendants shall be collectively referred to “Defendants NATURE OF CASE 1. By this action, Crews, a well-known actr from the television series Brooklyn 99 and The Expendables Film series seck to hold Vent and, his employer, WME, accountable for the Februaty 4, 2016 olatant and unprovoked sexual assault perpetrated by Venit on Crows, a petson who Venit hac never even met before, when Vent, upon his first meeting Crews, viously rabbed Crews” penis and testicles so hard that it caused Crews immediate pain ina blatant and unprovoked sexual assault. 2, This sexual assault occured at an entertainment industry event where Venit was representing WME fer whom Venit serves as high-ranking executive as head ofits highly lucrative motion piture department and personally represents several Als clients, including, among others, Adan Sandler, Sylvester Stallone, Eddie Murphy, Casey AMlck, Bret Rater, and Dustin Hoffman, Altiough Crews, a WME client himself, informed his WME agent, Bred Slater (Slater, of the sexual assault the very next day, shockingly, WME took no action a that time against Venit for a seal assault on a WME client likely because Veni isa significant ‘maneymaker for WME, As such, WME ratified and condoned the sexual assault and therefore ‘encouraged Venits sexual predatory behavior and allowed « known sexual predator to remain at WME to prey on other WME clients using Venit's and WME’s extraordinary power inthe clertainment industry to conceal his misdeeds. 3, tis now time to hold Venit accountable for his sexual predatory behavior and to hold WME accountale forts conduct in condoning, ratifying, and encouraging Verits sexual predatory bchavior. Indeed, a message needs to be Sento those in power who abuse those over “whom they exert infltence and conte! that abusive and sexual predatory behavio will not be tolerate. uw 2 2 a 4 2s 26 n fay 28 = | Sills ent iin Gaze, GM) FRA? up PARTIES AND VENUE 4, Crewsis and at all imes relevant hereto was, an individual residing in Los Angeles County, California, Crews is well-known actor fom the television series Brooklyn 99 and Everyone Loves Chris, and The Expendable fie series, among others. 5. Crewsis informed and believes tha Vents, and at all imes relevant hereto was, an individual residing in Los Angeles County, California, 6 Crewsis informed and believes that WME is, and at all mes relevant hereto was, «Delaware limite lisbility company dang business in Los Angeles County, California, with a rincipal place of business at 9601 Wilshire Boulevard, Third Floor, Beverly Hills, California. At all relevant ies, Veni was employed by WME as its head of motion picture department and ‘Crews is informed and belive that Veni has an ownership interest in WME, 7. The identities of Defendants named herein as DOES 1 to 25 are presently unknown and are therefore sued by their fictitious names. When the identities of said Defendants become known, Crews wil sek leave af cour to inser those trve names and identities. 8 Crewsis informed and believes that each Defendant herein, inclusive of but not limited to DOES | 1025, sand tall times herein relevant was the agent, employe, joint ‘entre, alter ego, stocestr in interest licensee, servant and partner ofeach and every other Defendant, and as such was and is responsible forthe ation and inaction ofeach and every other Defendant as alleged herein, Said Defendants and each of them knew of and approved and encouraged, or therafer ratified, the conduct, action, and inaction of each and every other Defendant which gives rise to ibility to Crews, and as such each and every Defendant diretly and proximately caused Crews’ damages, and is responsible for them, as having acted in furtherance ofthe action and inaction alleged herein JURISDICTION AND VENUE 9. Pursusnt to Aticle VI, Section 10 ofthe California Constitution, subject mater jutisicton is properin the Superior Court of California forthe County of Los Angeles mW Wy 8 B n gat an Say —— 10, Pursuant to Civil Procedure Code sections 395.5, venue is proper inthe Superior Court of California fer the County of Los Angeles because this is where Venit committed the sexual assault on Crews. GENERAL ALLEGATIONS, A. WME Is One Of The Most Powerful Cé [he Entertainment Industry And Veni Is A Senor Executive At WME, 11, WMBis one of the largest and most powerfil companies in the entertainment industry with its headquarters in Los Angeles and operating throughout the world, WME was formed in 2009 through a merger ofthe Wiliam Moris Agency, a talent agency founded in 1898, and th upstert Endeavor Talent Agency, founded in 1995, which was singled out by The New York Times for its roputation for “ferocity and barely bridled ambition.” Since then, WME has

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