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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.
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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
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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
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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.
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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
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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.
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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
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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-
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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
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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,
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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.
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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,
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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
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‘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
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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
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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
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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.
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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.
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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
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trial by jury.
Dated: December 3, 2015
By:
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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
Callman Gottesman, Maria Mattiello and Paul J. Peyser v. General Motors Corporation and E. I. Du Pont de Nemours & Company, 436 F.2d 1205, 2d Cir. (1971)