Case Document 1 Filed 06/02/16 Page 1 of 22 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA MACON DIVISION TITI PIERCE, Plaintiff, Case No. (LJA) V. TRIAL BY JURY DEMANDED WARNER BROS. ENTERTAINMENT, INC. Defendant. COMPLAINT COMES NOW Plaintiff, Titi Pierce, and states her Complaint against Defendant, Warner Bros. Entertainment, Inc. (?Warner Bros?), as follows: INTRODUCTION 1. This Complaint arises from Defendant?s intentional or reckless misconduct in connection with a segment entitled ?What ?5 Wrong with These These Signs?? that aired on The Ellen DeGeneres Show (?the Show?) on February 22, 2016 and again on April 15, 2016 (?the segment?). 2. During the segment, Defendant displayed a picture of one of Ms. Pierce?s real estate signs (she is a real estate agent) and referred to Ms. Pierce as a derogatory term, speci?cally calling her ?titty Pierce? instead of by her name ?Titi Pierce.? Case Document 1 Filed 06/02/16 Page years of life, no one has ever referred to Ms. Pierce as ?titty? until Defendant did so on February 22, 2016 on national television. Prior to Defendant?s misdeeds, Ms. Pierce had been called only by her name ?Titi,? which, as grammar dictates, is pronounced 4. As intended, Defendant?s name calling led to immediate ridicule and raucous laughter from the show?s live and television audiences. 5. In addition to calling Ms. Pierce a derogatory term, Defendant also displayed Ms. Pierce?s personal cell phone number on the screen for its national audience. Defendant did so even though it took the time to blur out a second phone number that appeared on the bottom of the real estate Sign. 6. As a result, following the airing of the segment, Ms. Pierce?while in the midst of attending a family funeral out-of-state?began receiving ridiculing and harassing telephone calls and voice mail messages, which continued at all hours of the day and night. 7. In addition, Ms. Pierce and her family have faced repeated ridicule on the streets of her hometown (Warner Robins) regarding the segment. 8. Ms. Pierce reached out to Defendant multiple times after the segment ?rst aired to inform Defendant that (1) Ms. Pierce?s ?rst name is ?Titi? and not ?titty?; (2) Ms. Pierce?s personal cell phone number was displayed on national Case Document 1 Filed 06/02/16 Page 3 of 22 television; and (3) Defendant?s actions had caused Ms. Pierce much pain and suffering. 9. Defendant blurred out Ms. Pierce?s personal telephone number on a Video of the segment that was live on the show?s website and eventually blurred out Ms. Pierce?s personal telephone number on a video of the segment that was live on the show?s Facebook page. 10. Despite actual notice of the false statements and the pain and suffering caused from those statements and the airing of Ms. Pierce?s personal cell phone number, Defendant aired the segment again on April 15, 2016?still calling Ms. Pierce a derogatory term and still airing Ms. Pierce?s personal cell phone number to the nation. 11. As a result of Defendant re-airing the segment, Ms. Pierce again received repeated ridiculing and harassing telephone calls and she and her family again faced ridicule and harassment on the streets of Warner Robins. PARTIES 12. Ms. Pierce is an individual who resides in Warner Robins, Georgia. 13. Warner Bros. is a corporation organized and existing under the laws of the State of Delaware with its principal place of business being located at 400 Warner Boulevard, Burbank, California 91522. Case Document 1 Filed 06/02/16 Page 4 of 22 14. Among its corporate activities, Warner Bros. produces and publishes The Ellen DeGeneres Show. JURISDICTION AND VENUE 15. Ms. Pierce is a citizen of the State of Georgia for purposes of diversity jurisdiction under 28 U.S.C. 1332. 16. Warner Bros. is a citizen of either Delaware or California for purposes of diversity jurisdiction under 28 U.S.C. 1332. 17. This Court has original subject matter jurisdiction of this action pursuant to 28 U.S.C. 1332 as there exists complete diversity of citizenship between Ms. Pierce and Warner Bros. and the amount in controversy exceeds Seventy?Five Thousand Dollars exclusive of interest and costs. 18. Viacom is subject to the jurisdiction of this Court pursuant to 28 U.S.C. 1332. 19. Venue is proper in this Court pursuant to 28 U.S.C. 1391. FACTUAL BACKGROUND Ms. Pierce and her name 20. Titi Pierce is an electronics engineer at Robins Air Force Base in Warner Robins. She is also a real estate agent in the Warner Robins area. 21. As grammar dictates, Ms. Pierce?s ?rst name, ?Titi,? is pronounced Case Document 1 Filed 06/02/16 Page 5 of 22 22. ?Titi? is a Nigerian name that means ??ower.? Ms. Pierce?s mother selected this name with care after consulting with a Nigerian book of names that her good friend shared with her. Ms. Pierce has strong, positive feelings toward her name for this reason. 23. In her entire 35 years of life, no one has ever referred to her as ?titty.? 24. That all changed after Defendant invaded Ms. Pierce?s privacy by airing a false, defamatory, and personally hurtful segment about her on February 22, 2016. Warner Bros. airs a segment on the Ellen DeGeneres Show that publicly humiliates Ms. Pierce 25. Warner Bros. publishes The Ellen DeGeneres Show to a nationwide audience. 26. On February 22, 2016, Defendant aired its ?What?s Wrong with These These Signs?? segment for the ?rst time. 27. The segment included a portion that consisted of a series of pre-taped photographs and Ms. DeGeneres?s commentary, which was pre-planned as well. 28. The segment displayed one of Ms. Pierce?s real estate signs with her name and personal cell phone number prominently displayed across the top. A second phone number appearing on the bottom of the sign was blurred out. Case Document 1 Filed 06/02/16 Page 6 of 22 29. Just before showing Ms. Pierce?s real estate sign, Defendant displayed a sign reading ?Nipple Convalescent Home? to orient the audience toward thoughts of breasts. 30. While displaying the real estate sign, Ms. DeGeneres paused and said ?titty Pierce, sounds like she might have spent some time in that nipple home, I don?t know.? 3 1. Simply showing the real estate sign with Ms. Pierce?s name would likely not have garnered any laughter if Defendant had not ?rst oriented the audience to elicit the response it desired, which was ridicule of and laughter toward Ms. Pierce. 32. Prior to the airing of the show and segment, Defendant developed its plan to orient the audience to ridicule and laugh at Ms. Pierce by displaying the ?Nipple Convalescent Home? sign immediately prior to showing Ms. Pierce?s real estate sign. 33. Without that orientation, it is unlikely anyone would have laughed when shown Ms. Pierce?s real estate Sign. 34. Ms. Pierce has lived her life as Titi for 35 years and until Defendant?s malicious actions on February 22, 2016, no one has ever referred to her as ?titty.? 35. With the exception of the portion of the segment discussing Ms. Pierce, the entire segment referred to businesses and not individuals. Case Document 1 Filed 06/02/16 Page 7 of 22 36. Ms. Pierce did not see the initial airing of the segment. At the time the segment ?rst aired, she was traveling to a family funeral in Tampa, Florida. 37. While driving to Tampa, during the wake, and at the funeral itself, Ms. Pierce?s personal cell phone rang constantly with out-of-state numbers she did not recognize. 38. She answered several of the telephone calls and when she did, she was met with cruel voices laughing uncontrollably, asking if she was a real person, and repeatedly shouting ?titty Pierce.? 39. Ms. Pierce was extremely confused, insulted, and was also personally grieving over the loss of her family member. Because of several callers telling her that they learned about her from The Ellen DeGeneres Show, she eventually learned of the full content of the segment. 40. After she stopped personally answering the barrage of telephone calls, she received several harassing and ridiculing voice mail messages. 41. One caller left a message explaining that Ellen DeGeneres was ?smart enough? to display Ms. Pierce?s real estate Sign, but ?not smart enough? to block out Ms. Pierce?s personal cell phone number. The caller wanted Ms. Pierce to know that if she got ?about a hundred thousand phone calls, that?s why.? And indeed, Ms. Pierce received many ridiculing and harassing telephone calls and voice mail messages. Case Document 1 Filed 06/02/16 Page 8 of 22 42. One caller mockingly told Ms. Pierce in a voice mail message that her ?size DD, 37 bra is ready.? 43. One caller told Ms. Pierce in a condescending voice mail message that she should change her name. 44. One caller left this repugnant message for her: your name is titty Pierce, titty, Ellen DeGeneres told me to call you, 45. Ms. Pierce also received multiple ridiculing and harassing text messages as a result of the segment. 46. Ms. Pierce?s co-workers also had to ?eld multiple ridiculing and harassing telephone calls following Defendant?s airing of the segment. The real estate of?ce where Ms. Pierce works as an agent received so many telephone calls that it was forced to issue the following statement on its company Facebook page to try to ward off callers: ?Loving that our own Titi Pierce of CBRF [Coldwell Banker Robbins Free] was on the Ellen DeGeneres show, but wish it was because they knew how fabulous and classy Titi is and not to poke fun. We love you Titi and are proud to have you in the CBRF Family.? 47. Once Ms. Pierce was back in Warner Robins, she was forced to endure repeated ridicule on the streets of her hometown. 48. People repeatedly approached Ms. Pierce on the street to laugh at her. Case Document 1 Filed 06/02/16 Page 9 of 22 49. Ms. Pierce experienced repeated ridicule at work about the segment. 50. Ms. Pierce?s husband also was forced to endure repeated ridiculing comments about his wife. 51. One of her fellow real estate agents informed her that people were talking about the segment all over town and that several people had posted about it on Facebook. 52. Ms. Pierce does not have a Facebook account so she asked her niece show her the post, which linked to the show?s Facebook page and a video of the segment. 53. The comments were mostly vile and very hurtful to read. 54. One of Ms. Pierce?s friends had commented directly to the show?s Facebook post that it had Ms. Pierce?s name wrong and that Ms. Pierce was a ?real person with real feelings.? Yet the show was not deterred from continuing to promote the segment. Ms. Pierce directly informs The Ellen DeGeneres Show that she was humiliated by the segment and that they got her name wrong 55. Ms. Pierce reached out to Defendant twice after the segment initially aired seeking redress from its malicious conduct??rst on February 24, 2016 and again on March 14, 2016. Case Document 1 Filed 06/02/16 Page 10 of 22 56. Ms. Pierce informed Defendant that her ?rst name was pronounced and not ?titty,? even though the rules of grammar should have so informed Defendant. 57. Ms. Pierce also called Defendant?s attention to the fact that while Defendant had blurred out a second telephone number on the bottom of the real estate sign, it prominently displayed Ms. Pierce?s personal cell phone number, which the show?s television audience had seen and used to repeatedly ridicule and harass Ms. Pierce. 58. Defendant blurred out Ms. Pierce?s personal telephone number on a Video of the segment that was live on the show?s website and eventually blurred out Ms. Pierce?s personal telephone number on a video of the segment that was live on the show?s Facebook page. 59. Ms. Pierce also asked Defendant to cease and desist from further reference to her on the show or social media. Despite direct knowledge of its wrongs and the resulting harm, Defendant repeated the segment on The Ellen DeGeneres Show with no changes 60. Defendant was aware of how to pronounce the name ?Titi? prior to airing the segment on February 22, 2016. But at least as of February 24, 2016, Defendant was on direct notice from Ms. Pierce that Defendant had not called Ms. Pierce by the correct name in the segment. 10 Case Document 1 Filed 06/02/16 Page 11 of 22 61. Defendant knew that it wrongfully displayed Ms. Pierce?s personal cell phone number to a national television audience prior to airing the segment on February 22, 2016. But at least as of February 24, 2016, Defendant was on direct notice from Ms. Pierce that Defendant had prominently displayed her personal cell phone number to the nation. 62. Despite this direct knowledge, on April 15, 2016, Defendant again aired the offending segment without making any changes. The portion of the segment displaying Ms. Pierce?s real estate sign, including her personal cell phone number, and calling Ms. Pierce a derogatory term, remained. 63. As a result, Ms. Pierce again received repeated ridiculing and harassing telephone calls. And Ms. Pierce and her family were forced to endure a fresh assault in social media and around her hometown. CLAIMS FOR RELIEF COUNT I FALSE LIGHT INVASION OF PRIVACY 64. Ms. Pierce incorporates by reference paragraphs 1?63 of this Complaint as though the same were set forth herein in their entirety. 65. Defendant invaded Ms. Pierce?s privacy when it splashed a real estate sign containing her name and personal cell phone number across the nation?s television screens While calling her a derogatory term to invoke laughter and ridicule during a segment of the Ellen DeGeneres Show on February 22, 2016. 11 Case Document 1 Filed 06/02/16 Page 12 of 22 66. Ms. Pierce?s ?rst name is Titi. 67. As grammar dictates, Ms. Pierce?s ?rst name is pronounced 68. Ms. Pierce?s ?rst name is not pronounced ?titty.? 69. Defendant knew Ms. Pierce?s name was not pronounced ?titty.? Thus, it oriented the audience toward this pronunciation by showing a sign displaying the word ?nipple? just before showing Ms. Pierce?s real estate sign. 70. Defendant invited the television audience to draw a false connection between Ms. Pierce and a ?nipple house? by wondering aloud as to whether Ms. Pierce had visited a ?nipple home.? 71. The gist of the segment was that Ms. Pierce?s name was the act of piercing a human nipple. 72. It is highly offensive to an ordinary person to be called ?titty? on national television. 73. It was highly offensive to Ms. Pierce to be called ?titty? on national television. 74. Defendant knew it was an invasion of Ms. Pierce?s privacy to display her personal cell phone number. 75. Indeed, Defendant blurred out another phone number appearing on the same real estate sign showing Ms. Pierce?s personal cell phone number. 12 Case Document 1 Filed 06/02/16 Page 13 of 22 76. After repeated communications on behalf of Ms. Pierce asking that her personal cell phone number not be displayed, Defendant blurred out Ms. Pierce?s personal cell phone number on the show?s website and social media site. 77. However, Defendant aired the segment again on April 15, 2016, again showing Ms. Pierce?s personal cell phone number with no blurring. 78. Despite repeated communications on behalf of Ms. Pierce directly informing Defendant of Ms. Pierce?s correct name, Defendant aired the segment again on April 15, 2016, again calling Ms. Pierce a derogatory term instead of by her name. 79. Defendant knew or should have known how to pronounce Ms. Pierce?s ?rst name prior to airing the segment in which Defendant referred to Ms. Pierce by a derogatory term that exposed her to ridicule and humiliated her across the country and in her hometown. 80. Defendant published the segment calling Ms. Pierce a derogatory term while at the same time advertising her personal cell phone number to a national television audience and pro?ted therefrom. 81. As a direct and proximate result of Defendant?s conduct, Ms. Pierce has suffered public ridicule, which has harmed her both professionally and personally. 13 Case Document 1 Filed 06/02/16 Page 14 of 22 82. As a direct and proximate result of Defendant?s conduct, Ms. Pierce has suffered stress, emotional distress, embarrassment, humiliation, anger, and other mental pain and suffering. 83. Defendant?s conduct demonstrates willful misconduct and an entire want of care that raises a conscious indifference to consequences. 84. Ms. Pierce is also entitled to an award of punitive damages from Defendant in order to punish it for its unlawful conduct and to penalize and deter it from repeating such unlawful and egregious conduct. COUNT II MISAPPROPRIATION OF LIKENESS 85. Ms. Pierce incorporates by reference paragraphs 1-84 of this Complaint as though the same were set forth herein in their entirety. 86. Defendant appropriated Ms. Pierce?s identity, particularly her name and personal cell phone number for its use in ridiculing Ms. Pierce by calling her a derogatory term during a segment of the Ellen DeGeneres Show that aired on February 22, 2016 and again on April 15, 2016. 87. Defendant displayed Ms. Pierce?s name and personal cell phone number without her knowledge or permission. 88. Defendant published the segment calling Ms. Pierce a derogatory term while at the same time advertising her personal cell phone number to a national television audience and pro?ted therefrom. l4 Case Document 1 Filed 06/02/16 Page 15 of 22 89. As a direct and proximate result of Defendant?s conduct, Ms. Pierce has suffered public ridicule, which has harmed her both professionally and personally. 90. As a direct and proximate result of Defendant?s conduct, Ms. Pierce has suffered stress, emotional distress, embarrassment, humiliation, anger, and other mental pain and suffering. 91. Defendant?s conduct demonstrates willful misconduct and an entire want of care that raises a conscious indifference to consequences. 92. Ms. Pierce is also entitled to an award of punitive damages from Defendant in order to punish it for its unlawful conduct and to penalize and deter it from repeating such unlawful and egregious conduct. COUNT - DEFAMATION 93. Ms. Pierce incorporates by reference paragraphs 1-92 of this Complaint as though the same were set forth herein in their entirety. 94. Defendant intentionally or recklessly called Ms. Pierce a derogatory term to invoke laughter and ridicule during a segment of The Ellen DeGeneres Show on February 22, 2016. 95. Ms. Pierce?s ?rst name is Titi. 96. As grammar dictates, Ms. Pierce?s ?rst name is pronounced 15 Case Document 1 Filed 06/02/16 Page 16 of 22 97. Ms. Pierce?s first name is not pronounced ?titty? 98. Defendant referred to Ms. Pierce as ?titty? instead of her actual first name, which is ?Titi.? I 99. It was false and derogatory of Defendant to refer to Ms. Pierce as ?titty.? 100. Defendant knew Ms. Pierce?s name was not pronounced ?titty.? Thus, it oriented the audience toward this pronunciation by showing a sign displaying the word ?nipple? just before showing Ms. Pierce?s real estate sign. 101. Defendant invited the television audience to draw a false connection between Ms. Pierce and a ?nipple home? by wondering aloud as to whether Ms. Pierce had Visited a ?nipple home.? 102. The gist of the segment was that Ms. Pierce?s name was the act of piercing a human nipple. 103. Defendant knew it was derogatory to refer to Ms. Pierce as ?titty.? 104. Defendant knew that referring to Ms. Pierce as ?titty? would expose Ms. Pierce to public ridicule. 105. Indeed, it was Defendant?s purpose to ridicule Ms. Pierce during the segment. 106. Defendant not only intended and knew that Ms. Pierce would suffer public ridicule as a result of calling her ?titty,? but also Defendant explicitly 16 Case Document 1 Filed 06/02/16 Page 17 of 22 invited a television audience to contact Ms. Pierce and ridicule her ?voice to voice? by displaying her personal cell phone number to the nation. 107. Defendant blurred out another phone number appearing on the same real estate sign, but not Ms. Pierce?s personal cell phone number. 108. After repeated communications on behalf of Ms. Pierce asking that her personal cell phone number not be displayed, Defendant blurred out Ms. Pierce?s personal cell phone number on the show?s website and social media site. 109. However, Defendant aired the segment again on April 15, 2016, again intentionally showing Ms. Pierce?s personal cell phone number with no blurring. 110. Despite repeated communications on behalf of Ms. Pierce directly informing Defendant of Ms. Pierce?s correct name, Defendant aired the segment again on April 15, 2016 without any changes. 111. As a direct and proximate result of Defendant?s actions in airing the segment on April 15, 2016, Ms. Pierce was ridiculed across the nation and in her hometown. 1 12. Defendant knew or should have known how to pronounce Ms. Pierce?s ?rst name prior to airing the segment in which Defendant referred to Ms. Pierce by a derogatory term that exposed her to ridicule and humiliated her across the country and in her hometown. l7 Case Document 1 Filed 06/02/16 Page 18 of 22 113. Defendant published the segment calling Ms. Pierce a derogatory term to third parties and the segment was, in fact, Viewed by third parties all across the United States. 114. As a direct and proximate result of the false and defamatory statements about Ms. Pierce, her personal and professional reputations have been permanently damaged. 115. As a direct and proximate result of the false and defamatory statements about Ms. Pierce, she has suffered special damages. 116. As a direct and proximate result of Defendant?s false and defamatory statements, Ms. Pierce has suffered public ridicule, which has harmed her both professionally and personally. 117. As a direct and proximate result of Defendant?s false and defamatory statements, Ms. Pierce has suffered stress, emotional distress, embarrassment, humiliation, anger, and other mental pain and suffering. 118. Defendant?s conduct demonstrates will?al misconduct and an entire want of care that raises a conscious indifference to consequences. 119. Ms. Pierce is also entitled to an award of punitive damages from Defendant in order to punish it for its unlawful conduct and to penalize and deter it from repeating such unlawful and egregious conduct. 18 Case Document 1 Filed 06/02/16 Page 19 of 22 COUNT IV INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 120. Ms. Pierce incorporates by reference paragraphs 1?1 19 of this Complaint as though the same were set forth herein in their entirety. 121. Defendant intentionally or recklessly called Ms. Pierce a derogatory term to invoke laughter and ridicule during a segment of The Ellen DeGeneres Show on February 22, 2016. 122. As a direct and proximate result of Defendant?s actions in airing the segment on February 22, 2016, Ms. Pierce was ridiculed across the nation and in her hometown. 123. Ms. Pierce?s ?rst name is Titi. 124. As grammar dictates, Ms. Pierce?s ?rst name is pronounced 125. Ms. Pierce?s ?rst name is not pronounced ?titty.? 126. Defendant knew Ms. Pierce?s name was not pronounced ?titty.? Thus, it oriented the audience toward this pronunciation by showing a sign displaying the word ?nipple? just before showing Ms. Pierce?s real estate sign. 127. Defendant invited the television audience to draw a false connection between Ms. Pierce and a ?nipple home? by wondering aloud as to whether Ms. Pierce had visited a ?nipple home.? 19 Case Document 1 Filed 06/02/16 Page 20 of 22 128. The gist of the segment was that Ms. Pierce?s name was the act of piercing a human nipple. 129. It is highly offensive to an ordinary person to be called ?titty? on national television. 130. It was highly offensive to Ms. Pierce to be called ?titty? on national television. 131. Defendant knew it would in?ict emotional distress upon Ms. Pierce by displaying her personal cell phone number to a national audience. 132. Indeed, Defendant blurred out another phone number appearing on the same real estate sign showing Ms. Pierce?s personal cell phone number. 133. After repeated communications on behalf of Ms. Pierce asking that her personal cell phone number not be displayed, Defendant blurred out Ms. Pierce?s personal cell phone number on the show?s website and social media site. 134. However, Defendant aired the segment again on April 15, 2016, again intentionally showing Ms. Pierce?s personal cell phone number with no blurring. 135. Despite repeated communications on behalf of Ms. Pierce directly informing Defendant of Ms. Pierce?s correct name, Defendant aired the segment again on April 15, 2016 without any changes. 20 Case Document 1 Filed 06/02/16 Page 21 of 22 136. As a direct and proximate result of Defendant?s actions in airing the segment on April 15, 2016, Ms. Pierce was ridiculed across the nation and in her hometown. 137. Defendant knew or should have known how to pronounce Ms. Pierce?s ?rst name prior to airing the segment in which Defendant referred to Ms. Pierce by a derogatory term that exposed her to ridicule and humiliated her across the country and in her hometown. 138. Defendant published the segment calling Ms. Pierce a derogatory term while at the same time advertising her personal cell phone number to a national television audience and pro?ted therefrom. 139. As a direct and proximate result of Defendant?s conduct, Ms. Pierce has suffered public ridicule, which has harmed her both professionally and personally. 140. As a direct and proximate result of Defendant?s conduct, Ms. Pierce has suffered stress, emotional distress, embarrassment, humiliation, anger, and other mental pain and suffering. 141. Ms. Pierce is also entitled to an award of punitive damages from Defendant in order to punish it for its unlawful conduct and to penalize and deter it from repeating such unlawful and egregious conduct. 21 Case Document 1 Filed 06/02/16 Page 22 of 22 CLAIM FOR RELIEF 142. Ms. Pierce demands: Trial by jury; That judgment be entered against Defendant for compensatory damages in an amount to be determined at trial; (0) That judgment be entered against Defendant for punitive damages to punish and penalize Defendant and deter Defendant from repeating its unlawful conduct in an amount to be determined at trial; That Defendant cease and desist from further publication of the segment on television or any websites or social media that it controls; That all costs of this action be assessed against Defendant; and That this Court award such other relief as it deems equitable, just, and proper. Respect?illy submitted this 2nd day of June 2016. Is! Stacey Godli?cy Evans Stacey Godfrey Evans Georgia Bar No. 298555 S.G. Evans Law, LLC 1180 West Peachtree Street Suite 2400 Atlanta, Georgia 30309 404-891-1402 678-868-1230 (fax) 22 IS 44 (mum) Case 06/02/16 Page 1 of 1 The .IS 44 civil cor-'cr sheet and the container! replace nor supplement the filing and service of pleadings or other papers as required by law, except as pruyirlerl by Int-.11 rules. T1115 Iiir?rl't, approved by the Judicial Hrll'IL'. United States in September 1974. rs required for the use ofthe Clerk of Court for the purpose of initiating the civil docket sheet. HF FORM) I PLAINTIFFS DEFEN DANTS A Titi rerce Warner Bros. Entertainment, Inc. County of Residence of First Listed Plaintiff County of Residence ofFirst Listed Defendant Delaware or California (EXCEPTIN US. PLAINTIFF CASES) (IN US. PLAINTIFF CASES Y) NOTE: IN LAND CON DEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED. (C) Altorlicys (Firm Name. Address. and Telephone Nrriirber) Attorneys ([f'Known) Stacey Godfrey Evans, S.G. Evans Law, LLC 1180 West Peachtree Street, Suite 2400. Atlanta, GA 30309 404-891-1404 ll. (Place an in One Bar Only) (Place an in One Box Plenum (For Diversify Cums Only) and One Box for Dq??ndam) 1 S. Government [3 3 Federal Question PTF DEF PTF DEF Plaintiff (US. Governmer Not a Party) Citizen of This State I I Incorporated or Principal Place 0 4 4 of Business In This State Cl 2 S. Govemment 5 4 Diversity Citizen ofAnother State {3 2 I3 2 Incorporated and Principal Place Cl 5 5 Defendant {Indicate in'zenslup quarrics in from of Business In Another State Citizen or Subject ofa 13 3 13 3 Foreign Nation CI 6 CI 6 For?eiulr ourth IV. (Place in One 301 tin-IN} 1 CONTRACT BANKRUPTCY 0m 51' 1 3 110 Insurance PERSONAL INJURY PERSONAL INJURY CI 625 Drug Related Seizure E1 422 Appeal 2% USC 158 ?3 375 False Claims Act 3 120 Marine El 310 Airplane El 365 Personal Injury - of Property 21 USC 881 El 423 Withdrawal 376 Qui Tam (31 USC 3 130 Miller Act CI 315 Airplane Product Product Liability CI 690 Other 28 USC 157 3729(a)) 53 140 Negotiable Instrument Liability 13 367 Health Care" 3 400 State Reapportionment :1 150 Recovery 15320 Assault. Libel Pharmaceutical i le?l 3 410 Antitrust Enforcement of udgrnent Slander Personal Injury 820 Copyrights TI 430 Banks and Banking:I 151 Medicare Act CI 330 Federal Employers? Product Liability El 830 Patent 3 450 Commerce :1 152 Recovery ofDefaulted Liability I3 368 Asbestos Personal I3 840 Trademark CI 460 Deportation Student Loans E1 340 Marine Injury Product 470 Racketeer In?uenced and (Excludes Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY Corrupt Organizations 153 Recovery Liability PERSONAL PROPERTY I3 710 Fair Labor Standards El 861 I 39511) 53 480 Consumer Credit ofVetemn?s Bene?ts E1 350 Motor Vehicle El 370 Other Fraud Act 13 862 Black Lung (923) 23 490 Cable/Sat TV 1611 Stockholders? Suits CI 355 Motor Vehicle I3 371 Truth irt Lending El 720 Labor/Management 863 (405(g1) 850 Securities/Comorodiliesi '3 190 Olhcr Contract Product Liability Cl 330 Other Personal Relations 13 864 8311) Title XVI Exchange 3 195 Contract Product Liability I3 360 Other Personal Property Damage CI 740 Railway Labor Act I3 865 RSI (405(g1) -3 890 Other Statutory Actions 196 Franchise Injury CI 385 Property Damage El 751 Family and Medical 3 891 Agricultural Acts 362 Personal Injury - Product Liability Leave Act 893 Environmental Matters Medical Malpractice El 790 Other Labor Litigation CI 895 Freedom of Information 1 REAL PROPERTY CIVIL. RIGHTS PRISONER PETITIONS El 791 Employee Retirement FEDERAL TAX SUITS Act 3 210 Land Condemnation [3 440 Other Civil Rights Haheas Corpus: Income Security Act El 870 Taxes (US Plaintiff 3 896 Arbitration 3 220 Foreclosure Cl 441 Voting El 463 Alien Detainee 3 899 Administrative Procedure 3 230 Rent Lease Ejectrnent 13 442 Employment El 510 Motions to acatc 13 871 IRS?Third Party Act/Review or Appeal of ?3 240 Torts to Laird I3 443 Housing! Sentence 26 USC 7609 Agency Decision 245 Tort Product Liability Accommodations 1'1 530 General 3 950 Constitutionality of 3 290 All Other Real Property CI 445 Amer. waisabiIiliL-s - 535 Death Penalty State Statutes Employment Other: I3 462 Naturalization Application El 446 Amer. w/Disahilities - I3 540 Mandamus Other [3 465 Other Immigration Other 550 Civil Rights Actions 448 Education 555 Prison Condition 13 560 Civil Detainee Conditions of Con?nement V. (Pluto (in in One Box Only) I Original 111 2 Removed from C1 3 Remandcd from C1 4 Reinstath or Cl 5 Transferred from El 6 Multidistrict Proceeding State Court Appellate Court Reopened Anotipir District Litigation (.13.!ch 1' Cite the .8. Civil Sliilult.? under which you are ?ling (Do not cite jurisdictional statutes unless diversity). 28 VI. CAUSE OF ACTION Ilion ofcausefalse ligh Invasron of privacy; misappropriation of likeness; defamation; intentional in?iction of emotional distress V11. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND CHECK YES only if delnanded in complaint: COMPLAINT: UNDER RULE 23, .mrw DEMAND: a Yes No RELATED 1- -): IF 66 it rm. tons JUDGE DOCKET NUMBER DATE SIGNATURE OF ATTORNEY OF RECORD 06/02/2016 Isl Stacey Godfrey Evans FOR OFFICE USE ONLY RECEIPT it AMOUNT APPLYING IFP JUDGE MAG. JUDGE