Genie Harrison, SBN 163641 Amber Phillips, SBN 280107 FILED Mary Olszewska, SBN 268710 Superior Court of Cali GENIE HARRISON LAW FIRM, APC County of Los Aneel 523 W. 6" Street, Suite 707 Los Angeles, CA 90014 OEC 12 2018 T: (213) 805-5301 F: (213) 805-5306 Sherri R. Garter, ExcquuyettticeriCh [email protected] eriClerk, [email protected] pt, Deputy ‘[email protected] rice Offa Attorneys for PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGEL! case N48 ST CVO8 468 JANE DOE, an individual, vs. COMPLAINT FOR: ) ) ) } ) Discrimination & Harassment HARVEY WEINSTEIN, an individual; THE) (NYCHRL §§8-101er seg.) WEINSTEIN COMPANY, LLC, a Delaware ) 2, Retaliation (NYCHRL §§8-101er Corporation; THE WEINSTEIN COMPANY } seq.) HOLDINGS, LLC, a Delaware Corporation Assault ) Sexual Battery ) Negligent Supervision and Retention } Gender Violence in Violation of Cal. 5 Civ. Codeg 52.4 ) ) Defendants. ane DEMAND FOR JURY TRIAL F ACTION 1. PLAINTIFF JANE DOE (“PLAINTIFF” or “DOE”), through her attorneys, the Genie Harrison Law Firm, APC, brings this action against Defendants HARVEY WEINSTEIN WEINSTEIN”), THE WEINSTEIN COMPANY, LLC, and THE WEINSTEIN COMPANY HOLDINGS, LLC (collectively “PWC”, seeking statutory, compensatory, and punitive damages, penalties DEI interest as allowed by law, costs, attorney: fees, and other appropriate and just relief for ENDANTS? unlawful conduct, Wh COMPLAINT ale2. PLAINTIFF is informed and believes, and based thereon alleges, that like many other victims, WEINSTEIN lured PLAINTIFF onto his infamous casting couch in his TWC office, into his hotel rooms, dinners, and to industry events, all in TWC’s name and paid for by TW ', where he manipulated, harassed, flashed, groped, fondled, sexually battered, forcibly performed oral sex, sexually assaulted, and threatened PLAINTIFF'S safety and career. While these meetings were set purportedly to discuss TWC scripts and included promises of parts and opportunities in TWC’S films (which would catapult PLAINTIFF'S career to another level), in reality, WEINSTEIN orchestrated the meetings as a scheme to accost PLAIN F and to keep her silent about his sexual abuse. 3. Atal times relevant, PLAINTIFF is informed and believes, and based thereon alleges, that TWC knew PLAINTIFF was a victim of WEINSTEIN’S predatory behavior, and facilitated and concealed it. ‘THE PARTIES. JURISDICTION, AND VENUE 4, DEFENDANT WEINSTEIN, upon information and belief, at all times mentioned herein resided in New York City, New York and/or Los Angeles, California. Upon information and belief, WEINSTEIN’S house was New York City, New York, although he often travelled to and/or resided in luxury hotels including the Waldorf Astoria in Park City, Utah, the Peninsula in Beverly Hills, California, and other locations. 5. Atall times relevant herein, WEINSTEIN was a Director and co-Chairman of DEFENDANT THE WEINSTEIN COMPANY and was, until he was fired on approximately October 8, 2017 6. DEFENDANTS THE WEINSTEIN COMPANY LLC and THE WEINSTEIN COMPANY HOLDINGS LLC are Delaware Limited Liability Companies whose principle places of business are in New York City, in the County of New York (Collectively referred to as “TWC”). TWC| also had an office in Los Angeles, California, at 9100 Wilshire Blvd., Beverly Hills, California. 7. TWC is an employer or employment agency within the meaning of California law and the New Yor k City Human Rights Law (“NYCHRL”). 8. PLAINTIFF is a professional actress who was 22 years old when she met WEINSTEIN in 2013. Atall times relevant herein, PLAINTIFF resided in New York C New York. She currently ‘COMPLAINT -2-Seow rae)e resides in Los Angeles County, California, Jane Doe is a pseudonym to protect PLAINTIFF’S privacy, 9. The California Superior Court has jurisdiction over this action under California Constitution Article VI, Section 10, which grants the Superior Court “original jurisdietion in all causes except those given by statute to other trial courts.” 10. ‘This Court has jurisdiction and venue is proper over this action as certain wrongful conduct and resulting damages occurred in Los Angeles County, California, LL, Following commencement of this action, a copy of this Complaint will be served both on the New York City Commission on Human Rights and the Office of the Corporation Counsel of the City of New York, thereby satisfying the notice requirements of the New York City Administrative Code. EACTS COMMON TO ALL CAUSES OF ACTION 12. In January 2013, PLAINTIFF first met WEINSTEIN during the Sundance Film Festival in Park City, Utah, at which she provided him her card “in case there are any opportunities for auditions.” 13. ‘The next day, WEINSTEIN’S TWC assistant called PLAINTIFF and WEINSTEIN invited her to his suite at the Waldorf Astoria Park City, allegedly fo discuss a potential film. About two hours into the meeting and discussions about the film project, PLAINTI F excused herself to use the restroom, While PLAINTIFF was iting on the toilet, with her tights around her ankles, WEINSTEIN opened the bathroom door and walked in on PLAINTIFF, who wa’ immobilized with by embarrassment ~ thinking he entered accidently — which quickly changed to terror as WEINST IN unbuttoned his jeans, dropped his pants to the floor, and exposed his penis while telling her “I like looking at you,” “my dick is nice and hard for you,” and asking “do you like my dick?", and instructing her “let me look at you.” 14. Despite PLAINTIFF replying “no,” WEINSTEIN moved closer to her while masturbating. Eventually he moved so close that he was towering over her and was close enough to try to pull up her jacket and eventually ejaculated directly onto her skirt, When he was finished masturbating, he called her “a great girl” and joked about how that was so fiun and told her that as Jong COMPLAINT ese