Professional Documents
Culture Documents
2018 Michael Chiesa V Conor Mcgregor Et Al Complaint Amended 9
2018 Michael Chiesa V Conor Mcgregor Et Al Complaint Amended 9
518314/2018
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 12/20/2018
SUPPLEMENTAL Summons
Defendants.
You are hereby summoned to answer the complaint in this action, and to serve a
of your answer, of if the complaint is not served with this summons, to serve a
copy
notice of appearance on the plaintiff's attorney(s) within twenty days after the services
of this summons exclusive of the day of service, where service is made by delivery upon
you personally within the state, or within 30 days after completion of service where
service is made in any other manner. In case of your failure to appear or answer,
judgment will be taken against you by default for the relief demanded in the complaint.
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CONOR McGREGOR
3 Churchfield
The K Club
Straffan
CO. Kildare
W23 YP30
5 Pembroke Row
Dublin 2
DO2 FW61
BARCLAYS CENTER
620 Atlantic Avenue
Brooklyn, NY 11217
Brooklyn, NY 11217
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MICHAEL CHIESA,
Plaintiff,
AMENDED VERIFIED
- against- COMPLAINT
----
Defendants.
JOSEPH W. MURRAY, ESQ., upon information and belief, respectfully shows to this
THE PARTIES
"CHIESA"
(hereinafter, or "plaintiff") was and still is a resident of the State of
Washington.
2. That at all times hereinafter mentioned, plaintiff CHIESA was and still is a
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9. That at all times hereinafter mentioned, defendant MSE, through its agent
defendant McGREGOR and others, including defendant JOHN DOES 1-20, committed
the tort and/or torts that are the subject of this lawsuit within the State of New York.
agent of MSE.
promotor of MSE.
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behalf of MSE.
soliciting business for MSE within the State of New York and elsewhere.
14. That at all times hereinafter mentioned, defendant JOHN DOES 1-20 are
defendant McGREGOR.
15. That at all times hereinafter mentioned, defendant JOHN DOES 1-20 are
CENTER, LLC (hereinafter, "BEC") was and still is a domestic and/or foreign
17. That at all times hereinafter mentioned, defendant BEC is doing business
Atlantic Avenue, County of Kings, State of New York (hereinafter "the subject
location").
19. That at all times hereinafter mentioned, the defendant BEC, d/b/a
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20. That at all times hereinafter mentioned, the defendant BEC owned the
subject location.
21. That at all times hereinafter mentioned, the defendant BEC leased and/or
22. That at all times hereinafter mentioned, the defendant BEC operated the
subject location.
23. That at all times hereinafter mentioned, the defendant BEC maintained the
subject location.
24. That at all times hereinafter mentioned, the defendant BEC controlled the
subject location.
25. That at all times hereinafter mentioned, the defendant BEC managed the
subject location.
BROOKLYN, LLC (hereinafter, "AEG") was and still is a domestic and/or foreign
corporation
doing business in the State of New York.
27. That at all times hereinafter mentioned, the defendant AEG operated the
subject location.
28. That at all times hereinafter mentioned, the defendant AEG maintained
29. That at all times hereinafter mentioned, the defendant AEG controlled the
subject location.
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30. That at all times hereinafter mentioned, the defendant AEG managed the
subject location.
31. That at all times hereinafter mentioned, defendants JOHN DOES 21-50 are
BARCLAYS, whose job duties include but are not limited to matters and the
swurity
protection of both patrons and performers at BARCLAYS and/or BEC and /or the
subject location.
32. That at all times hereinafter mentioned, defendants JOHN DOES 21-50 are
employees and/or agents of defendant AEG, whose job duties include but are not
limited to matters and the protection of both patrons and performers at the
security
33. That at all times hereinafter mentioned, all JOHN DOES identified herein
are identified as such, names being fictitious, because their true identifies are unknown
at this time.
THE FACTS
competitor.
36. That at all times hereinafter mentioned, Lobov competes in the UFC.
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UFC.
39. That prior to April 3, 2018, it was reported that Lobov had been making
40. That on or about April 3, 2018, Nurmagomedov crossed paths with Lobov
in a Brooklyn hotel, and inquired about Lobov's disparaging and insulting comments
about Nurmagomedov. This incident was recorded and posted on YouTube on April 4,
saw the above-refereñced YouTube video, and then sent Lobov a text message stating,
"I'm on the way, I'm coming over, and I don't care what, when, who, why. I don't give
over."
a f**k. You're brother and I'm on the [Source: sportsjoe.ie, Patrick
my way by
McCarry.]
some or all of the defendant JOHN DOES 1-20, and together they boarded a plane from
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43. That the aircraft that was used to transport defendant McGREGOR and
JOHN DOES of the defendant JOHN DOES 1-20 was owned and/or leased and/or
operated and/or managed and/or controlled and/or charted and/or paid for by MSE.
44. That at some point after arriving in New York City, on April 5, 2018,
defendant McGREGOR and defendants JOHN DOES 1-20 proceeded to the subject
location with the intent to assault, harass, intimidate, threaten, injure, maim, and/or
45. On April 5, 2018, an event was taking place at the subject location known
as "UFC 223 Media Day", at which plaintiff CHIESA, Nurmagomedov, and other UFC
JOHN DOES 1-20, knowingly entered and/or remained unlawfully in the loading dock
47. That defendant McGREGOR individually, and behalf of MSE, and JOHN
DOES 1-20, forcefully entered and/or remained unlawfully in the loading dock area of
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individuals, were located within two busses inside the dock of the subject
loading
location.
50. Defendant McGREGOR and defendants JOHN DOES 1-20 were present at
the loading dock of the subject location, without permission and/or authority, where
51. Plaintiff CHIESA and Nurmagomedov were occupying the same bus, one
defendants JOHN DOES 1-20 surrounded and/or swarmed the subject bus.
defendants JOHN DOES 1-20 yelled expletives and threatening and intimidating
defendants JOHN DOES 1-20 attempted to board the subject bus and prevent it from
moving, causing plaintiff and others to experience fear, apprehension, confusion, and
terror.
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defendants JOHN DOES 1-20 kicked the exterior of the subject bus multiple times and
punched the exterior of the subject bus multiple times, thunderous sounds, and
creating
and defendants JOHN DOES 1-20 threw objects and dangerous instruments directly at
the subject bus windows, thunderous sounds, and plaintiff and others
creating causing
57. These acts caused great emotional distress, including but not limited to,
58. Having failed to shatter the glass of the windows of the subject bus up
until this time, defendant McGREGOR, and on behalf of MSE, and other
individually
defendant JOHN DOES 1-20, ran through the loading dock, seeking
an instrument that
was heavy
enough to shatter the windows of the subject bus.
and/or hand truck, lifted same over his head, as he ran towards the bus, hurled
dolly
the and/or hand truck into a window of the subject bus, causing the window to
dolly
60. Plaintiff was seated in the subject bus at the seat that was adjacent to the
window that defendant McGREGOR shattered. The glass from the shattered window,
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and the hand truck itself, struck the plaintiff, severe facial lacerations and other
causing
injuries.
61. The act of shattering the glass window adjacent to the plaintiff, causing
plaintiff, caused serious physical injury to the plaintiff, but not limited to, a
including
metal chairs and barricades, and hurled them at the bus, causing additional
including
attack the bus and its occupants, a total disregard for the injuries that he
showing
encouraged, and solicited others to attack the bus and its occupants, including
violently
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66. Defendants JOHN DOES 1-20 conspired with each other and with
67. Throughout all of the aforementioned events, defendant BEC, BEC d/b/a
BARCLAYS, defendant AEG, and defendants JOHN DOES 21-50, failed to act to
prevent defendants McGREGOR individually and on behalf of MSE, and JOHN DOES
68. Throughout all of the aforementioned events, defendant BEC, BEC d/b/a
BARCLAYS, defendant AEG, and defendants JOHN DOES 21-50, failed to adequately,
initiated by
McGREGOR individually and on behalf of MSE, and JOHN DOES 1-20.
69. Throughout all of the aforementioned events, defendant BEC, BEC d/b/a
70. Throughout all of the aforementioned events, defendant BEC, BEC d/b/a
BARCLAYS, defendant AEG, and defendants JOHN DOES 21-50, could have and
should have intervened, reacted, prevented the attacks, and/or otherwise protected the
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71.
By his own admission, defendant McGREGOR, individually and on behalf
of MSE, engaged in the aforementioned conduct and acts with the premeditated intent
and sought to promote his brand and profit from his criminal activity. See, McGregor
Interview, September 20, 2018, Rockefeller Center, moderatedbyDana White, UFC CEO:
Reporter: When you're in that situation, that everyone has now seen on video,
multiple times, what's through your head - you're in that dock,
going loading
you have a dolly in your hand...?
McGregor: I just thank the lord Jesus Christ that that man [Nurmagomedov] had
not got the balls to foot off that bus, because trust me, OR, that the bus door
step
did not open, because if that bus door had opened, this man [Nurmagomedov]
would be dead right now. He would be in a box, and I would be in a cell, and
we would not have this great fight ahead of us, so... there are many things I can
speak on about that about the lead up, about emotions, and things
incident, my
like that, BUT, there's still situations involved in it. So, I'm just
many ongoing
here to compete on October 6, in Las Vegas Nevada, T-Mobile Arena, live on
Pay
Preview, UFC 229 in Association with McGregor Sports and Entertainment and
72. An MMA fight event known as UFC 2232 was scheduled to be held at the
73. The main event of the UFC 223 card3 WaS the UFC lightweight
1 12"
"Proper No. is an Irish whisky manufacturing company founded by McGREGOR.
2 UFC fights events are titled at the time of the subject the next fight to
chronologically; incident,
take place was 223, two days after the subject event. UFC 229, wherein McGREGOR was to
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and featherweight champion Max Holloway and Nurmagomedov (who is now the
74. Also, at UFC 223, plaintiff was scheduled to compete in the lightweight
75. Plaintiff had trained hard, cut weight, and was prepared for this
optimally
face, plaintiff was unable to and/or precluded from competing in his scheduled fight
depression, and other emotional damages; plaintiff further was damaged due to the lost
UFC.
78. Had plaintiff been able to partidpate in UFC 223, it would have and/or
3 "cani"
A is a list of matches, i.e., a roster of fighters, competing in each fight throughout the
event.
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79. On April 6, 2018, Max Holloway was pulled from the main event, due to
unrelated medical reasons and a replacement was needed for the main event
80. But for the injuries plaintiff suffered from the vicious and violent attack
Nurmagomedov in the main event Championship Title Fight of UFC 223. This fact was
confirmed via text message to plaintiff from a UFC executive corporate officer.
in the main event Champiombip Title fight against Nurmagomedov for the lightweight
depression, and other emotional damages; plaintiff was additionally damaged due to
the lost opportunity, suffered additional substantial economic damages, and suffered
and on behalf of MSE, has profited off of his criminal activity described
individually
herein, specifically: defendant McGREGOR has promoted himself, MSE, and other
corporate entitles owned and/or controlled by him, including but not limited to an Irish
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whisky manufacturing company known as Proper No. 12, using the criminal events
descried hereinbefore.
used the criminal events described hereinbefore at press conferences and other
promotional outlets, to promote himself and/or companies for which he owns and/or
behalf of MSE, knowing that a fight with Nurmagomedov was impending in the
professional MMA upcoming fight known as UFC 229, McGREGOR purposely staged
and engaged in the criminal acts of April 5, 2018, in a deliberate attempt to create
publicity resulting from the havoc, mayhem, and injury that he caused, in this reckless
publicity stunt, and promotional effort for this fight, with the intent to profit
upcoming
from same, with a complete disregard for the injuries he would have caused and did
cause fear, terror, and injury, he would profit from those acts at a later
believing greatly
time.
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using the criminal activity, for promotional purposes for UFC 229, in an effort to
increase interest, increase ticket sales, increase PayPerView sales, and promote his new
whiskey company Proper No. 12, with the intent to profit from same.
89. Plaintiff was and continues to be injured in this process and continues to
suffer damages.
90. Under the Son of Sam law, defendant McGREGOR individually and on
contained in the paragraphs set forth above with the same force and effect as if more
93. Pursuant to Executive Law §632-a(1)(a), a crime is defined as, "any felony
state"
defined in the laws of the and "the act or acts the offense occurred in
constituting
state."
whole or in part in this
crime..."
committed the
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"victim of a crime".
Sam"
96. "Son of Law encompasses persons charged with or convicted of State
law offenses. New York State Crime Victims Bd. V.T.M. Productions, Inc., 1998, 176
Misc.2d 777, 673, NYS2d 871, affirmed 265 A.D.2d 38, 705 N.Y.S.2d 320, issued 2000 WL
261103.
Penal Law §145.05(2), Criminal Mischief in the Third Degree, a class E-felony; Penal
Law §145.10, Criminal Mischief in the Second Degree, a class-D felony; Penal Law
the Third Degree, a class-A misdemeanor, and eight other crimes, including assault,
individually, and/or on behalf of MSE, is profiting from his crimes and should be
disgorged of same as plaintiff is entitled to those profits; pursuant to the Son of Sam
disgorged of profits they received from UFC 229, Proper No. Twelve, and any other
source of profits.
additional crimes, but not limited to: Attempted Murder in the second
including
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degree, pursuant to Penal Law §§110/125.25(1) and (2) which are class-B violent felony
degree, pursuant to Penal Law §120.07, which is a class-C violent felony; Attempted
Assault in the first degree, pursuant to Penal Law §§120.10(1), (2), (3), and (4), which are
class-C violent felonies; Burglary in the Second Degree, pursuant to Penal Law
§§140.25(1)(b) and (c) which are class-C violent felonies; Assault in the Second Degree,
pursuant to Penal Law §§120.5(1) and (2), which are class-D violent felonies; Recldess
Endangerment in the First Degree, pursuant to Penal Law §120.25(1)(b) which is a class-
D felony.
contained in the paragraphs set forth above with the same force and effect as if more
101. That at all times hereinafter mentioned, the defendants BEC, BEC d/b/a
BARCLAYS, AEG, and/or JOHN DOES 21-50 owed a duty to plaintiff to engage in
proper measures and actions, to protect the plaintiff and other patrons of the
security
subject location, and failed to do same. These defendants breached that duty.
102. That at all times hereinafter mentioned, the defendants BEC, BEC d/b/a
BARCLAYS, AEG, and/or JOHN DOES 21-50 owed a duty to plaintiff to see that its
employees, agents, servants, representatives, or other, use reasonable care to protect the
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plaintiff and others at the subject facility, to prevent an unreasonable risk of harm to
plaintiff, and others similarly situated. These defendants breached that duty.
individually, and/or on behalf of MSE, and JOHN DOES 1-20 owed a duty to plaintiff
104. That the aforementioned occurrence and the results thereof including the
injuries sustained by the plaintiff were caused by and due to the negligence,
control their conduct, to take actions and/or precautions which would have
failing
105. That by reason of the foregoing, and due to the carelessness, recklessness
and negligence of the aforementioned defendants, plaintiff has been injured and
suffered damages, both general and special, in an amount that exceeds the jurisdictional
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contained in the paragraphs set forth above, with the same force and effect as if more
107. That each and all of the defendants herein had a duty of care to the
plaintiff; that said duty was breached by the defendants; that said breach resulted
in emotional harm.
directly
emotional distress; and there lies a causal connection between the conduct and injury;
109. That defendants engaged in extreme and outrageous conduct against the
causing, severe emotional distress; there exists a direct causal connection with the
conduct of the defendants and the injuries suffered by plaintiff, including but not
defendants'
110. That actions goes beyond all possible bound of decency, and
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infliction of emotional distress against the plaintiff, and the plaintiff has suffered
damages pursuant thereto, and he will continue to suffer same in the future.
which exceeds the jurisdictional limits of all lower courts which would otherwise have
jurisdiction.
contained in the paragraphs set forth above with the same force and effect as if more
114. That on the aforementioned date at the subject location, plaintiff was,
McGREGOR individually, and/or on behalf of MSE, and JOHN DOES 1-20, causing
JOHN DOES 1-20 did intentionally attempt or threaten to inflict injury on plaintiff, with
an apparent ability to cause the harm, and that said actions created a reasonable
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contained in the paragraphs set forth above, with the same force and effect as if more
117. That the aforesaid occurrence and resulting injuries to plaintiff were due
to the willful, wanton, reckless and/or malicious conduct of the defendant McGREGOR
defendants.
and JOHN DOES 1-20, without cause or provocation, battered the plaintiff, causing
DOES'
and JOHN 1-20 intentional touching of, or application of force to the body of the
plaintiff, in a harmful and offensive manner, and without the plaintiff's consent, caused
behalf of MSE and JOHN DOES 1-20, exhibited a depraved indifference for human life
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121. That by reason of the foregoing, and the malicious and intentional acts of
20, plaintiff has been injured and suffered damages, general, special, and punitive, in an
amount that exceeds the jurisdictional limits of all lower courts which would otherwise
have jurisdiction.
contained in the paragraphs set forth above, with the same force and effect as if more
intentionally caused severe emotional distress and bodily harm to the plaintiff.
124. That the acts of defendants described herein were an intentional infliction
of emotional distress against the plaintiff, and the plaintiff has suffered damages
behavior, caused severe emotional distress, mental trauma, and/or bodily harm to the
plaintiff; that defendants engaged in extreme and outrageous conduct; with an intent to
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there lies a causal connection between the conduct and injury; and severe
resulting
emotional distress.
126. That defendants engaged in extreme and outrageous conduct against the
severe emotional distress; there is exists a direct causal connection with the conduct of
the defendants and the injuries suffered plaintiff, but not limited to
by including
defendants'
127. That actions goes beyond all possible bound of decency, and
damages which exceeds the jurisdictional limits of all lower courts which would
ACTION'
AS AND FOR A SEVENTH CAUSE OF
NEGLIGENT HIRING, RETENTION, AND SUPERVISION
AND RESPONDEAT SUPERIOR
129. Plaintiff repeats, reiterates and re-alleges each and every allegation
contained in the paragraphs set forth above, with the same force and effect as if more
130. Defendants BEC, BEC d/b/a BARCLAYS, and/or AEG, placed their
employees, JOHN DOES 21-50 in a position to cause foreseeable harm, harm which the
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plaintiff would have been spared had the employer taken reasonable care in
DOES'
and/or AEG knew or should have known of JOHN 21-50 propensity for the
employment when they failed to properly execute their duties, failed to protect the
plaintiff, failed to prevent defendant JOHN DOES 1-20 from entering an area in which
132. Defendant JOHN DOES 21-50 were performing actions to further their
employer's interest, or to carry out duties incumbent upon the employ in furthering the
employer's business.
which exceeds the jurisdictional limits of all lower courts which would otherwise have
jurisdiction.
134. Plaintiff repeats, reiterates and re-alleges each and every allegation
contained in the paragraphs set forth above, with the same force and effect as if more
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punished for his shocking, outrageous, and violent criminal conduct and should be
made to set an example in order to deter him and others from committing similar
criminal acts of violence in the future. The circumstances herein constitute such
of MSE, stem from spite, malice, vanity, greed, and other evil motives, and contained a
others'
conscious and deliberate disregard of the plaintiff's and interests and/or safety,
evincing a depraved indifference to human life, safety, and good and moral behavior.
hereiñ is but one example of a long sordid history of similar violent and egregious
conduct for which he has been subject of litigation and has had to compensate his
civilized society. Thus, substantial punitive damages herein are warranted at this time.
malicious and intentional acts of the defendants herein, plaintiff MICHAEL CHIESA
has been rendered sick, sore, lame and disabled; that he has experienced pain, suffering
and a loss of enjoyment of life and will experience same in the future; that he has been
obliged to expend, and will continue to expend in the future, sums of money for
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medical aid and attention; he has experieñced substantial economic loss; that he has
forever lost professional opportunities that would have furthered and advanced his
career; that he was caused to be removed from a fighting competition that would have
generated substantial income and and would have furthered and advanced
opportunity
his career; that that he has suffered personal injuries, but not limited to
including
permanent scarring; that he has been unable to attend to his usual avocation and
activities, has suffered a loss and other benefits as a result and believes he will continue
amount that exceeds the jurisdictional limits of all lower courts which would otherwise
have jurisdiction, together with costs and disbursements of this action, and such other
and further relief as to this Court seems just proper and equitable.
Yours, etc.,
JOSEPH W. MURRAY, Esq.
Joseph W. Murray, Es .
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ATTORNEY VERIFICATIO_N
) ss.:
COUNTY OF QUEENS )
JOSEPH W. MURRAY, an
attorney duly licensed to practice law, affirms
under penalties of perjury, that I am the of record for the plaintiff in the within
attorney
action; that I have read the foregoing SUPPLEMENTAL SUMMONS AND AMENDED
VERIFIED COMPLAINT and know the contents thereof; that the same is true to my
belief, and as to those matters, I believe it to be true. The reason this verification is
made by me and not by plaintiff MICHAEL CHIESA is that the county in which
plaintiff resides is different than the in which deponent maintains his office.
county
EPH W. MURRAY, E .
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MICHAEL CHIESA,
Plaintiff
- against -
CONOR McGREGOR, McGREGOR SPORTS AND ENTERTAINMENT, LLC, JOHN DOES 1-20,
names being fictitious as unknown at this time, BROOKLYN EVENTS CENTER, d/b/a BARCLAYS
CENTER, AEG MANAGEMENT BROOKLYN, LLC, and JOHN DOES 21-50, names being fictitious,
as unknown at this time,
Defendants.
Law Offices Of
JOSEPH W. MURRAY, ESQ.
for Plaintiff
Attorney
PHONE: 718-514-3855
FAX: 646-514-4771
Pursuant to 22 NYCRR 130-L1, the undersigned, an attorney admitted to practiœ in the courts of New York
State, artifies that, upon information and and reasonable inquiry, the contentions contained in the
belief
annexed document are not frivolous.
Dated: 20
Dated: 20
Attorney(s) for: