Lisa Bloom (158458)
A. Douglas Mastroianni (150438)

SUPERIOR COURT OF THE

COUNTY OF LOS AN GELES

 

 

 

 

THE -

- FIRM

2 Vanessa Hooker (315270)
3 THE BLOOM FIRM
20700 Ventura Blvd, Suite 30-1
4 Woodland Hills, CA 91364
Telephone: (818) 914-7319
5 Email: Lisa@TheBloomFirm.com
6 Attorneys for Plaintiff ANGELA WHITE
7
9
10
11 ANGELA WHITE (aka BLAC CHYNA),
12 I Plaintiff.
13 V. 
14 ROBERT KARDASHIAN (aka ROB
KRIS 
15 KIMBERLY KARDASI-HAN (aka KIM
KARDASHIAN or KIM KARDASHIAN
16 KHLOE 
17 KOURTNEY KENDALL
KYLIE DOES 1-100,
18
Defendantsl?I 

 

CIVIL 

 

 



OCT 172017

Sh -
era 11. ham-a, UIHC

By: Marlon Gomez, Dept

STATE OF CALIFORNIA

IC680035

Case No:

CONIPLAINT FOR:
1. 

2. 

3. DISTRIBUTION OF PRIVATE
MATERIALS (Civil Code ?l708.85);

4. DOMESTIC VIOLENCE (Civil Code
?l708.6);

5. HARASSNIENT 527.6);

6. INTRUSION INTO PRIVATE




3. 

O-II

. 

1?

Errolerk



 

- 

9. DEFAMATIOELW 

10. INTERFERENCE WITH


11. INTERFERENCE --

ECONOMIC RELATIONS.

WHITE p: MRDASHMN

 

 

Plaintiff ANGELA WHITE (aka BLAC CHYNA), by and through undersigned counsel

1
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The Bloom Firm, brings this Complaint against Defendants ROBERT KARDASHIAN (aka

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ROB KARDASHIAN), KRIS JENNER, KIMBERLY KARDASHIAN (aka KIM

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KARDASHIAN or KIM KARDASHIAN WEST), KHLOE KARDASHIAN, KOURTNEY

5

KARDASHIAN, KENDALL JENNER, KYLIE JENNER, and DOES 1-100, and hereby

6

alleges as follows:
INTRODUCTION

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1.

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Rob Kardashian is an abuser intent on destroying Angela White, the mother of

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his baby, who left him in 2016. In revenge, the Kardashian-Jenner family became media

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predators, slut-shaming her on social media and killing her hit television show, which had

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already begun filming a second season.
2.

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After Ms. White obtained July 2017 court orders finding that Rob Kardashian’s

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revenge porn rant was a form of domestic abuse, and knowing that Ms. White was intent on

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standing up for her rights, Rob Kardashian and Kylie Jenner hastily filed this lawsuit, which

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attempts to shame her for: (i) having worked in the past as a stripper, a legal profession peopled

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by actual human beings as deserving of respect as their famous sisters, who perform in sex

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tapes and pose naked; (ii) having his baby—little Dream, who Ms. White could not possibly

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love more and who Ms. White, despite her many powers, did not conceive by herself; (iii)

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damaging a gingerbread house—really: a gingerbread house; and (iv) most of all, having the

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courage to leave him, a Kardashian, when she could no longer tolerate his harassment.
3.

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The unwritten rule no one told Ms. White when she embarked on a relationship

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with Mr. Kardashian is: the entire family1 takes it personally if you leave and will come after

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you, using their fame, wealth and power to take you down. They will get your television show

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cancelled. They will go after your endorsement deals. They will condone slut-shaming of

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you. 2 They will spread lies about you. They will claim you are a bad mother, without

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THE
BLOOM FIRM

Except Caitlyn Jenner, who had the decency to publicly admit, on an episode of “The View”
on July 14, 2017, that Rob Kardashian had a problem and mistreated Ms. White..
2
“Slut shaming” is an attempt to humiliate the victim, almost always female, by suggesting that
she has low morals and is disgusting and unworthy. (Cyberbullying Research Center, Revenge
2
1

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

evidence. They will even fund a lawsuit about crumbled cookies to get revenge on you for

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leaving a Kardashian.

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4.

Rob Kardashian and his powerful, vindictive family have done enough damage

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to Ms. White’s career and professional reputation, which she singlehandedly built from

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scratch—without the help of a famous last name. This lawsuit seeks to hold them accountable.

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PARTIES

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5.

Plaintiff ANGELA WHITE (aka BLAC CHYNA) (hereinafter “Ms. White”) is a

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California citizen, who currently resides in Los Angeles, California. Ms. White is an actress,

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reality television personality, business owner, model, and social media influencer. In addition

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to being a mother, starring in music videos and modeling for magazines, Ms. White owns an

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eyelash and beauty salon in Encino, California called Lashed and a beauty product line by the

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same name. Ms. White also owns 88 Fin, a women’s clothing line she established in 2013.

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6.

Defendant ROBERT KARDASHIAN, JR. (aka ROB KARDASHIAN)

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(hereinafter “Rob Kardashian”) is a California citizen, who currently resides and does business

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in Los Angeles, California. He is best known for appearing on “Keeping Up with the

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Kardashians,” his family’s hit reality television show on the E! network.

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7.

Defendant KRIS JENNER is Rob Kardashian’s mother and manager. Defendant

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Kris Jenner is a California citizen, who currently resides, owns property, and does business in

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Los Angeles. Defendant Kris Jenner is best known for starring along with her family on

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“Keeping Up with the Kardashians.” She also owns and operates Jenner Communications,

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which is located in Los Angeles.

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8.

Defendant KIMBERLY KARDASHIAN (aka KIM KARDASHIAN or KIM

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KARDASHIAN WEST) (hereinafter “Kim Kardashian) is Rob Kardashian’s sister. Defendant

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Kim Kardashian is an individual, who is a California citizen, who currently resides, owns

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property, and does business in Los Angeles. Defendant Kim Kardashian is a reality television

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THE
BLOOM FIRM

Porn Research, Laws, and Help for Victims (July 14, 2016) <http://cyberbullying.org/revengeporn-research-laws-help-victims> as of July 9, 2017.)
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CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

personality, socialite, actress, businesswoman, and model. She is best known for starring along

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with her family on the E! network’s “Keeping Up with the Kardashians.”

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9.

Defendant KHLOE KARDASHIAN is also Rob Kardashian’s sister. Defendant

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Khloe Kardashian is an individual, who is a California citizen and currently resides, owns

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property, and does business in Los Angeles. Defendant Khloe Kardashian is a reality television

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personality, socialite, model, and businesswoman, who is best known for starring along with

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her family on the E! network’s “Keeping Up with the Kardashians.”

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9

10.

Defendant KOURTNEY KARDASHIAN is Rob Kardashian’s oldest sister.

Defendant Kourtney Kardashian is a California citizen, who currently resides, owns property,

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and does business in Los Angeles, California. Defendant Kourtney Kardashian is a reality

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television personality, socialite, businesswoman, and model, who is best known for starring

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along with her family on the E! network’s “Keeping Up with the Kardashians.”

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11.

Defendant KENDALL JENNER is Rob Kardashian’s younger half-sister.

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Defendant Kendall Jenner is a California citizen, who currently resides, owns property, and

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does business in Los Angeles, California. Defendant Kendall Jenner is a reality television

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personality, socialite, businesswoman, and model, who is best known for starring along with

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her family on the E! network’s “Keeping Up with the Kardashians.”

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12.

Defendant KYLIE JENNER is Rob Kardashian’s younger half-sister. Defendant

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Kylie Jenner is a California citizen, who currently resides, owns property, and does business in

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Los Angeles, California. Defendant Kendall Jenner is a reality television personality, socialite,

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businesswoman, and model, who is best known for starring along with her family on the E!

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network’s “Keeping Up with the Kardashians.”
JURISDICTION AND VENUE

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13.

This Court has personal jurisdiction over Defendants Rob Kardashian, Kris

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Jenner, Kim Kardashian, Khloe Kardashian, Kourtney Kardashian, Kendall Jenner, and Kylie

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Jenner because each of the Defendants reside, do business, and/or own property in the State of

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California.

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 14.

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Venue is proper in Los Angeles County because Defendants reside and do

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business in this county, and the events, conduct, and injuries alleged herein occurred in this

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county.
STATEMENT OF FACTS

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5

I.

BLAC CHYNA: A PUBLIC PERSONA
15.

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Angela White is and has always been an independent self-sufficient woman.

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Unlike Rob Kardashian, Ms. White comes from working-class background, does not have a

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wealthy family to rely on and has always worked for a living.
16.

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In fact, Ms. White first began working when she was sixteen-years-old. When

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turned eighteen, Ms. White began performing as an exotic dancer to save money for college.

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Two years later, Ms. White moved to Miami to attend Johnson and Wales University, where

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she took classes during the day and performed at the King of Diamonds strip club at night.
17.

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From there, her modeling career took off and in 2011 Ms. White was deemed

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“model of the year” at the Urban Model Awards. It was also around this time that Ms. White

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began featuring in music videos and getting her name mentioned in songs by hit makers such as

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Kanye West, Nicki Minaj and Drake.
18.

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In 2013, Ms. White graduated from JLS Professional Makeup Artist School.

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Later that year, Ms. White launched her clothing line, 88 Fin, and her cosmetic line, LASHED

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by Blac Chyna. In 2014, Ms. White opened her LASHED Beauty Bar salon, which offers

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various beauty services and makeup lessons.
19.

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Ms. White created the public persona “Blac Chyna” and has been successful in

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her own right as an entertainer, social media influencer, and entrepreneur—long before she met

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Rob Kardashian.

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II.

RELATIONSHIP WITH ROB
20.

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Ms. White embarked on a romantic relationship with Rob Kardashian in or

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around January 2016. Shortly thereafter, their relationship became the target of tabloid media

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fodder.

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 21.

1

Despite the fact that Ms. White and Rob’s older sister, Defendant Kim

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Kardashian were once close friends, Rob’s famous family instantly disapproved of the new

3

relationship.
22.

4
5

announced Ms. White was pregnant with their first child in May 2016.
23.

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7

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On November 10, 2016, the couple welcomed their daughter Dream Renée

Kardashian to the world.
24.

8
9

In or around April 2016, the couple became engaged and shortly thereafter

In or around December 2016, Ms. White split from Rob Kardashian because of

his abuse and she and her children (she has a son, King, from a prior relationship) moved out of
the Calabasas home she briefly shared with Rob Kardashian. 3
25.

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On or around December 17, 2016, Rob Kardashian took to the social media

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application Snapchat to confirm their break-up to the world and said, “Chyna left me.”

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III.

DECEMBER 2016 SOCIAL MEDIA HACKING
26.

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Rob Kardashian has stolen Ms. White’s phone in the past. In fact, in December

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2016 Rob Kardashian took it one step further and hacked into Ms. White’s Instagram account to

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publicly shame her in retaliation for leaving him.
27.

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During their relationship, Rob Kardashian was often jealous and insecure so he

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would regularly go through Ms. White’s phone to see who she was contacting and what she was

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saying to them.
28.

20
21

Specifically, in or around December 2016, Rob Kardashian stole Ms. White’s

phone and impersonated Ms. White on her own Instagram page.
29.

22

While impersonating Ms. White on her Instagram page, Rob Kardashian made it

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seem like she was cheating on him by posting fake conversations with other famous men and

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made it seem as though Ms. White was speaking negatively about Defendant.

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3

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THE
BLOOM FIRM

At the time of their break-up Ms. White and Rob Kardashian were living in a home owned by
his youngest sister, Defendant Kylie Jenner.
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CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

30.

In one his many posts from Ms. White’s account, Mr. Kardashian posted a

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screen shot of a private conversation between Ms. White and her friend Jayden Smith with a

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caption that read, “Chyna and Jayden talking followed by Chyna giving Jayden her old 610 #.”

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In another post, Rob Kardashian posted an old photo of Ms. White and said,

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“Next I am going to post my messages with my best friend Treasure talking about my plans

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with Rob.”

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

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32.

He then posted a series of text messages between Ms. White and her friend

Treasure, in which Ms. White appears to describe Rob Kardashian as “lazy,” “fat” and
“insecure.”

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 33.

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Ms. White eventually changed her Instagram handle so that she could respond to

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Rob’s online attack on her own Instagram account. In her response, Ms. White said: “I’M

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DONE ! This entire year I have done nothing but help Rob! It’s so SAD & PATHETIC how

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low he’d stoop to cover up HIS PERSONAL ISSUES! Rob is mentally ill & refuses to seek

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help! He self medicates which makes it worse. I have done nothing but help & love him from

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the beginning! It’s Chy here I got my own!!! I was doing swell before I got with him!” Ms.

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White even detailed some of the abuse Rob had forced her to endure during their relationship

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by saying, “He stressed me out my ENTIRE PREGNANCY!!! Accusing me of cheating, going

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crazy on me with massive text blast daily! being an absolute lunatic & then covering it up with

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gifts! I was verbally abused every other day.”

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1
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IV.

DOMESTIC VIOLENCE ON APRIL 8, 2017
34.

Rob Kardashian has not only been verbally abusive but he has also been

physically violent with Ms. White in the past—even after their December 2016 break-up.
35.

On or around April 8, 2017, Rob Kardashian was angry with Ms. White and was

5

speaking poorly about her in front of Ms. White’s 4-year-old son, King. When Ms. White told

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Defendant Rob Kardashian that he could not speak about her this way in front of her young son,

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he exclaimed, “I can say whatever the fuck I want!”

8
9
10
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36.

Ms. White then used her phone to call King’s father, Tyga when Rob Kardashian

immediately grabbed the phone from her hand and violently knocked her to the ground where
she landed on her hands and knees.
37.

Rob Kardashian is large man of 6’2” and weighs 280 pounds whereas Ms. White

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is a petite woman of only 5’2”. Accordingly, Rob Kardashian easily knocked Ms. White to the

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ground in just one fell swoop.

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38.

Ms. White was terrified and

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injured as a result of Rob Kardashian knocking

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her to the ground. As a result, Ms. White texted

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King’s nanny and said, “Rob hit me. Come

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quick.” Ms. White’s 4-year-old son witnessed

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Defendant violently knock his mother to the

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ground.

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 39.

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After the nanny came and removed King from the violent situation, Ms. White

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asked to borrow the nanny’s phone so that she could document Rob Kardashian’s abuse as he

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had confiscated Ms. White’s phone.
40.

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With the nanny’s phone in hand, Ms. White ran to the bedroom and immediately

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locked her door. However, Rob Kardashian lost all control and tore the hinges off of Ms.

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White’s bedroom door. Ms. White then retreated to the bathroom, hid in the bathroom closet,

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and locked the door.

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41.

Rob Kardashian then followed Ms. White through the bedroom to the bathroom.

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It was then that Ms. White began to record Defendant’s abuse by peering around the closet door

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and through the glass in the bathroom door. Ms. White hid in the closet out of fear that he

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would break the glass bathroom door. In recording Rob Kardashian through the closet door she

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cracked open, a shirtless Rob Kardashian can be heard yelling, “Do you want your phone?!

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You can record me all you want, I don’t care!” (See Exhibit 1)

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 42.

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2

Rob Kardashian then went through Ms. White’s bedroom closet, ransacked it,

and threw her belongings into total disarray.

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43.

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Rob Kardashian’s domestic abuse of Ms. White on or around April 7, 2017 was

a truly terrifying experience for Ms. White.
44.

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Ms. White suffered pain and difficulty walking for days following the domestic

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dispute as a result of Rob Kardashian violently knocking her to the ground.

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V.

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ROB’S CONSTANT HARASSMENT
45.

Rob Kardashian has a long history of harassing Ms. White by text, email, phone,

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and social media dating back to June 2016—during their engagement when Ms. White was

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pregnant with their daughter.

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THE
BLOOM FIRM

46.

In or around June 2016, Ms. White called her ex fiancé Tyga to discuss a matter

regarding their son King. Upon learning that his pregnant fiancé called her son’s father, Rob
12
CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

Kardashian grew intensely jealous and accused Ms. White of cheating on him with Tyga. At

2

the time, Tyga was dating Rob’s sister Kylie and Ms. White no longer had romantic feelings for

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her him. Ms. White loved Rob and was focused on growing her family with him. However,

4

Rob never believed her and continued to accuse her of wanting to reconcile with Tyga even

5

during his July 5, 2017 social media rant.
47.

6

Ms. White first started telling Rob Kardashian to seek the help of a professional

7

therapist in or around June 2016. However, at no point during their romantic relationship, did

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Rob Kardashian seek the help of a professional therapist. 4
48.

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Despite the fact that Ms. White split from Rob Kardashian in or around

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December 2016, Defendant continued to relentlessly harass Ms. White by text, email, phone,

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and social media.

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49.

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Rob Kardashian sent the following abusive text messages in May 2017—months

after the couple broke-up.
50.

14

During Rob Kardashian’s harassing text messages, he said, “U wanted Dream to

15

get back at [Tyga] well u can have her. I’m gone for life.” In the same text message,

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Defendant repeatedly harassed Ms. White because her ex fiancé simply liked one of her photos

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on social media.

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THE
BLOOM FIRM

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In or around February 2017, Ms. White met daily with Jamel Davenport, who was supposed to
be Rob’s life coach as documented on episodes of his family’s show “Keeping Up with the
Kardashians.” While Ms. White worked on various exercises with Mr. Davenport, Rob
Kardashian regularly cancelled appointments and ultimately failed to accept Mr. Davenport’s
help.
13
CIVIL COMPLAINT

WHITE V. KARDASHIAN

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

51.

It was not uncommon for Rob Kardashian to threaten to kill himself in a sick

2

attempt to manipulate her. In another text message, Rob Kardashian said, “U think I’m playing

3

but I’m not. I don’t have a purpose for nobody. Not even u. I’m done and I’m gone.”

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

52.

In another harassing text, Rob said, “So don’t worry I’m gone for good . . .On

2

dreams life . . . I’ll be dead and u won’t get a single text from me again . . .” In response, Ms.

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White merely said, “Stop boy” as she typically kept her responses few and far between so as not

4

to provoke further harassment from Rob Kardashian.

5

53.

Rob Kardashian again threatened to take his own life when talking about a pair

6

of Nikes Ms. White gifted to him on his birthday and said, “It’s cool I’m not tripping on some

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nikes it’s just the point . . . Of how little u care about me . . . Which is why I am gonna be gone

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from your life very soon.” Rob Kardashian even doubled down on his threat in the same text

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thread and said, “Trust me I’m about to be gone from life.”

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

54.

Another time Rob Kardashian texted Ms. White asking why she was mad at him.

2

Rob texted, “Do u realize u treat me like complete shit and I still would do anything for u . . .

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What is your problem . . . I’m literally on the verge of killing myself and u couldn’t care less . .

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. Is that what it’s gonna take?”

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 55.

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Rob Kardashian would even continue to harass Ms. White even when she did not

2

respond to his text messages. In one text, as if egging her on, Rob said, “Hate how u treat me

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like shit . . . So that’s why u won’t say anything . . . R u too wasted to text? Is that why your

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mad?”

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

56.

In another texting rant, Rob Kardashian said, “What’s your problem? Nobody

2

coming at u at all. In fact u forgot to send me a pic once again after I said how pretty u looked.

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Why r u like this everyday . . .” Ms. White remained silent and did not respond.

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57.

Again, Defendant continued to harass Ms. White and said, “I just hope that tyga

5

treats Dream well not like what he said to u when she was still in your belly. And if u guys

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don’t want her my mom will be happy to be with her and love her.” In the same text message,

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Rob Kardashian went on to say, “So answer the one question that u been avoiding since last

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night . . . So I can at least die with knowing . . . Why didn’t u thank me on social media ? Was

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it cuz your man tyga be on u and u don’t want to ruin that ?” Again, Ms. White did not respond

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to Defendant’s harassment.

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

58.

Rob Kardashian continued to threaten to kill himself over multiple text messages

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because Ms. White would not explain why she did not thank him on social media for a red

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Ferrari he leased for her as a gift in or around May 2017. Defendant continued to rant, “Shit is

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wack as fuck man. Say something. I wanna know what it is. R u embarrassed of me. U was

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so happy to post the lambo before I didn’t even have to ask. I just wanna know why man so I

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can kill myself in peace.” Ms. White again did not respond.

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THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1
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59.

In another text message, Rob Kardashian said, “Yo. Stop this man. I been

asking u a question for almost 24 hours. To the point where u got me taking pills.”

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7
8
9
10
11
12
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14
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20
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24
25
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28
21

THE
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CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

60.

In another text message, Rob Kardashian sent a photo of him with a hand full of

2

pills—as if he was going to take his own life if Ms. White did not respond to his texts right at

3

that moment.

4
5
6
7
8
9
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12
13
14
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19
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23
24
25
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27
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22

THE
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CIVIL COMPLAINT

WHITE V. KARDASHIAN

 61.

1

Rob Kardashian was relentless in constantly harassing Ms. White such that when

2

Ms. White blocked one email address, Defendant simply created a new email address so that he

3

could continue harassing her.
62.

4

In the two months prior to Rob Kardashian’s social media rant on July 5, 2017,

5

Ms. White was forced to change her phone number at least three times to avoid Defendant’s

6

harassment and abusive attempts to manipulate her through threats of suicide.

7

VI.

ROB’S SOCIAL MEDIA ATTACK ON JULY 5, 2017
63.

8

After the December 2016 break-up, Ms. White moved into her own home. Ms.

9

White and Rob Kardashian were single people, living separate lives, and peacefully sharing

10

custody of their child. Ms. White occasionally dated, as Rob Kardashian presumably did as

11

well. However, in the midst of living their own separate lives, Rob Kardashian continued to

12

harass Ms. White with insistent text messages, emails, phone calls, and social media posts.
64.

13
14

On or around July 5, 2017, Rob Kardashian chose to launch a vicious social

media tirade designed to hurt and publicly shame Ms. White—the mother of his only child.
65.

15

On July 5, 2017, Rob Kardashian first took to his Instagram page to post revenge

16

porn while ranting against and publicly shaming Ms. White. When Rob Kardashian publicly

17

attacked Ms. White, not only did he have over nine million followers but his profile was

18

available for the public to view. As a result, it was not just Rob’s over nine million Instagram

19

followers that witnessed his social media attack on Ms. White but rather the entire world

20

witnessed it as well.
66.

21

Moreover, Rob Kardashian’s graphic, defamatory, and abusive social media

22

posts about Ms. White that day have forever been memorialized online as media outlets all over

23

the world took screen grabs and reposted them time-and-time again in reporting the story. 5 In

24

fact, on July 6, 2017, Rob Kardashian’s social media attack made “Poor Dream” a worldwide

25

trending topic on Twitter along with his and Ms. White’s names. Accordingly, Rob

26

Kardashian’s social media tirade made his daughter, her mother, and himself some of the most

27
5

28
THE
BLOOM FIRM

One day, Dream will be able to search online and see all that her father said about her mother,
including the post in which Rob accused Ms. White of having Dream “out of spite.”
23
CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

talked about and retweeted topics for days. According to July 2017 Google Trends, Ms. White

2

was the third most trending person on Google with Rob Kardashian coming in as fourth. In the

3

months following the July 5 attack, a Google search for “Rob Kardashian Revenge Porn Blac

4

Chyna” reveals that over 1.2 million news articles have been published online reporting on the

5

event.
67.

6

Rob Kardashian’s Instagram account, with over nine million followers, was

7

deleted by Instagram after he posted photos of Ms. White’s genitals, buttocks, and nipples. In

8

one post, Rob Kardashian said, “This is a pic Chyna just sent me before she fucked another man

9

in her house with my baby in the house and her son in the house. . .” 6 This statement was false

10

and specifically designed to harm Ms. White’s reputation by slut-shaming her.

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

The original image posted by Rob Kardashian was not censored with an emoji as that was later
added to the image by Instagram as a means of censoring the graphic nude photo.
6

24

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

68.

The truth is that Rob Kardashian and Ms. White had not been romantically

2

involved for months. Ms. White sent these private nude photos to her former fiancé after they

3

had broken-up and only because Rob Kardashian would beg for Ms. White to send him nude

4

photos, saying, “Quick go in the bathroom take [a] quick pic for me to cum to.” Ignoring him

5

did not work. Telling him to stop did not work. She thought giving him the photos he wanted

6

might work. Sadly, it did not.

7
8
9
10
11
12
13
14
15
16
17
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22
23
24
25
26
27
28
25

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 69.

1

Also on July 5, 2017, after being blocked from Instagram, Rob Kardashian,

2

undeterred and intent on inflicting the maximum harm on Ms. White, took to his Twitter

3

account with an “lol” (laugh out loud) and posted more nude photos of Ms. White. In this

4

posting, he cruelly taunted her: “And for all u wondering why her damn nipples are so damn

5

big thats cuz she had surgery after the baby was born on our anniversary January 25 that I paid

6

100k for and they really messed up on her nipples. Them shits used to be so cute and now they

7

so damn big!”
70.

8

In another one of Rob’s

9

posts on July 5, 2017, he shared a photo

10

of Ms. White’s nude rear-end and said,

11

“Whoa that’s crazy u let me cum inside

12

u and then another man do the same in

13

the same bed and the same robe and

14

everything in the house where I pay

15

16K rent. Sheesh. And so u know she

16

had her butt reduced but I know it still

17

looks wild.” At no time did Rob

18

Kardashian have Ms. White’s

19

permission to publish these photos or

20

information online, nor did Rob

21

Kardashian ever attempt to seek Ms.

22

White’s consent to share these photos or

23

her personal medical information before

24

he posted them for his millions of

25

Instagram and Twitter followers and the

26

rest of the world to see. 7

27
7

28
THE
BLOOM FIRM

The original image posted by Rob Kardashian was not censored with an emoji as that was
later added to the image by Instagram as a means of censoring the graphic nude photo.
26
CIVIL COMPLAINT

WHITE V. KARDASHIAN

 71.

1

Rob Kardashian continued to intentionally publicly shame Ms. White by posting

2

a picture and video of Ms. White in the hospital about to undergo surgery. In this post, he said,

3

“Everyone wonders how Chyna lost all that weight after the baby and she lies to everyone but

4

no I’m such a great husband that on our anniversary I paid 100K to do this surgery to get all

5

everything fixed . . .” This statement was false as (i) he was never her husband, and (ii) Ms.

6

White had not deceived anyone as to her cosmetic procedure.

7
8
9
10
11
12
13
14
15
16
17
18
19

72.

In fact, Rob Kardashian himself underwent weight loss surgery that cost

20

$100,000, whereas Ms. White’s surgery was for a lesser amount. Ms. White underwent minor

21

cosmetic procedures including a breast and butt reduction as well as a small amount of

22

liposuction around her belly button. Ms. White is a well-known social media influencer and

23

trendsetter, who professionally endorses health, lifestyle, and diet products on her Instagram

24

and Twitter accounts. Accordingly, the manner in which Rob Kardashian revealed Ms. White’s

25
26
27

personal medical information jeopardized Ms. White’s endorsement deals with several weight
loss, fitness, and diet companies—that all pay Ms. White to promote their products on social
media.

28
27

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

73.

Additionally, Rob Kardashian did not pay for Ms. White’s cosmetic procedure

2

out of the kindness of his own heart or because he was “such a great [h]usband.” In fact, Rob

3

Kardashian only paid the cost of the surgery upfront because he planned for the network to

4

reimburse him for the costs out of the budget from “Rob & Chyna” season two.

5

74.

Additionally, during his July 5 social media rant, Rob Kardashian threatened to

6

post online Ms. White’s residential address when he announced to the world the city she lives

7

in, and that she did not live in a gated community. Ms. White does not live in a gated

8

community and posting her residential address would endanger Ms. White and her two small

9

children. Rob Kardashian’s threat to expose Ms. White’s address truly terrified her as to her

10
11

own personal safety as well as that of her children.
75.

On information and belief, Rob Kardashian also posted a screen grab of a text

12

message conversation between Ms. White and him, in which Ms. White’s phone number was

13

revealed to the world. This required Ms. White to change her phone number yet again as a

14

result of Rob Kardashian’s wrongful conduct.

15

76.

Rob Kardashian’s social media rant on July 5, 2017, also contained numerous

16

false implications about Ms. White, which caused her to suffer harm both personally and

17

professionally.

18

77.

During his social media tirade, Rob Kardashian falsely implied that his romantic

19

relationship with Ms. White had only recently ended when he said, “But she couldn’t remain

20

loyal and cheated and fucked way too many people and she got caught and now this is all

21

happening and it’s sad.”

22

78.

In another post, Rob Kardashian again falsely implied that he and Ms. White

23

were currently in a relationship and that she had recently been unfaithful to him when he said,

24

“This is the dude Chyna got caught cheating on me with for a minute now . . . Just yesterday

25

Chyna sent me her pussy and everything and said she gonna come fuck me . . .” Ms. White and

26

Rob Kardashian broken-up in December 2016 and have not been romantically involved for

27
28
28

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

months. 8 Moreover, Ms. White did not tell Rob Kardashian that she was “gonna come fuck

2

[him].”

3
4
5
6
7
8
9
10
11
12
13
14
15
79.

16

Also on July 5, 2017 Rob Kardashian falsely stated that he paid $100,000 for

17

Ms. White’s alleged weight loss surgery. Rob Kardashian knew that falsely claiming that he

18

spent large sums of money on Ms. White’s cosmetic surgery would harm her reputation and

19

business relationships. Additionally, Rob Kardashian did not pay for Ms. White’s cosmetic

20

procedure out of the kindness of his own heart. In fact, Rob Kardashian only paid the cost of

21

the surgery upfront because he planned for the network to reimburse him for the costs out of the

22

budget from “Rob & Chyna” season two.
80.

23

At the time, Ms. White’s procedure was being filmed as part of the second

24

season of the “Rob & Chyna.” As part of the story line for “Rob & Chyna” season two, Ms.

25

White planned to discuss her struggles in dealing with her body-image issues, particularly as

26
27
28
THE
BLOOM FIRM

8

In fact, Rob Kardashian had recently sent Ms. White a text message in which he
acknowledged Ms. White informing him that she had been romantically involved with other
men as further proof that Rob Kardashian knew their relationship was long over.
29
CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

they pertained to the size of her rear-end after giving birth to Dream. During his July 5 social

2

media rant, Rob Kardashian made sure to falsely accuse Ms. White of undergoing weight-loss

3

surgery to lose weight after having Dream.

4

81.

In fact, Rob Kardashian acknowledged Ms. White’s endorsements on July 5,

5

2017, when he posted a meme containing a photo of himself dressed as Beyoncé with the words

6

“Flat Tummy Tea” on top. In the caption of the post, he Kardashian said, “You know I’m

7

coming with that heat: My Beyoncé lemonade album about to be fire.” In other words, Mr.

8

Kardashian was going to publicly shame Ms. White in an even bigger way for her perceived

9

infidelity – even though they were no longer in a relationship.

10
11
12
13
14
15
16
17
18
19
20
21
22
23

82.

During his July 5 social media tirade, Rob Kardashian knew that falsely accusing

24

Ms. White of undergoing “weight loss surgery” after giving birth to Dream would generally

25

damage her reputation as a social media influencer. Importantly, Rob Kardashian knew that

26

targeting a specific brand in his July 5 tirade would destroy Ms. White’s professional

27

relationship with that brand as a social media influencer.

28
30

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 83.

1

Most egregiously, on July 5, 2017, Rob Kardashian falsely stated that Ms. White

2

had her daughter “out of spite” and even suggested that Ms. White had her daughter in an effort

3

to seek revenge on ex fiancé Tyga. 9

4
5
6
7

84.

During his social media rant Rob Kardashian falsely claimed that he “never

8

once” cheated on Ms. White and that he “remained loyal to her even after all the cheating she

9

been doing and the multiple men she been fucking including [himself].” Ms. White did not

10

cheat on Rob Kardashian during their relationship. However, Ms. White did not refrain from

11

dating as a single woman in the time since her relationship with Rob Kardashian ended in

12

December 2016. She was a single woman and fully entitled to have a love life beyond Rob

13

Kardashian on July 5, 2017 when he falsely accused of her of engaging in infidelity.

14

85.

Rob Kardashian erroneously claimed that Ms. White chose drugs and sex rather

15

than spending the day with her daughter on her first 4th of July, when he posted, “Get it together

16

for your daughter. It was your daughter’s first 4th of July yesterday and u chose drugs and sex

17

in our bed rather [than] spending it with your daughter for her first 4th of July.” However, Ms.

18

White did not choose drugs and sex in lieu of spending time with her daughter on the 4th of

19

July. Since their split in December 2016, Rob Kardashian has had physical custody of their

20

daughter on Tuesdays—the exact day on which the 4th of July fell this year.

21

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22

///

23

///

24

///

25

///

26
27
28
THE
BLOOM FIRM

9

Rob Kardashian has regularly accused Ms, White of being in a relationship with him as a
means to get revenge on Tyga—this is a constant theme throughout Rob Kardashian’s
harassment of Ms. White.
31
CIVIL COMPLAINT

WHITE V. KARDASHIAN

 86.

1

In another post on July 5, 2017, Rob Kardashian falsely accused Ms. White of

2

withholding their daughter from seeing him. However, this claim was entirely false as

3

Defendant had custody of their daughter Dream on July 5, 2017—the very day he decided to

4

attack Ms. White on social media. Ms. White has never withheld Dream from her father.

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21

VII.

ROB’S PAST ABUSE OF WOMEN
87.

Rob Kardashian’s social media rant against Ms. White was not the first time he

22

took to social media to publicly shame one of his former girlfriends. Rob Kardashian has a

23

long history of publicly slut-shaming his exes on social media after break-ups.

24

A.

Rita Ora

25

88.

In or around December 2012, Rob Kardashian took his Twitter account to

26

publicly slut-shame Rita Ora, a pop star who briefly dated Rob in 2012. During Rob

27

Kardashian’s social media rant against Rita Ora, he said, “This is a lesson to all the young

28

women out there to not have unprotected sex with multiple men especially while in a
32

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

relationship.” Rob Kardashian continued on this rant against Ora and said, “But when a woman

2

disrespects herself by messing with more than 20 men all while being in a relationship with a

3

Faithful man . . . When a woman cheats on you with one man I can live with that. People make

4

mistakes, trust me. I have forgiven numerous times . . .”
89.

5

Even Rob’s sister, Defendant Khloe Kardashian, joined in on his social media

6

rant by indirectly ridiculing Ora by tweeting, “Cheaters never prosper @RobKardashian ill be

7

home today . . . Try and smile little brother.” Rob then continued his slut-shaming rant against

8

Ora and said, “I’m actually disgusted a woman could give up her body to more than 20 dudes in

9

less than a year’s time while trying to start a career.”
90.

10

Even Rob’s sister, Defendant Khloe Kardashian, joined in on his social media

11

rant by indirectly ridiculing Ora by tweeting, “Cheaters never prosper @RobKardashian ill be

12

home today . . . Try and smile little brother.” Rob then continued his rant against Ora and said,

13

“I’m actually disgusted a woman could give up her body to more than 20 dudes in less than a

14

year’s time while trying to start a career.”

15
16
17
18
19
20
21
22
23
24
25
26

///

27

///

28

///
33

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

85.

Rob Kardashian continued on his social media rant against Ora and said, “She

2

cheated on me with nearly 20 dudes while we were together, I wonder how many she will sleep

3

with now that we apart? But I mean 20?!!!”

4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20

86.

In responding to an alleged tweet deleted by Ora, Rob Kardashian said, “So you

let me get you pregnant and you let others hit raw?” Accordingly, Rob has demonstrated a
pattern of revealing ex-girlfriends’ sensitive medical information online in vengeful social
media posts after break-ups.
87.

While Rob Kardashian did not refer to Rita Ora directly by name in his tweets,

the public was well aware as to whom these attacks were aimed as the pop singer developed an
unflattering nickname “Rita Whora” that remained a worldwide trending topic the same day as
Rob’s social media rant.

21
22
23
24
25
26
27
28
34

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

B.

Adrienne Bailon

2

88.

Rob Kardashian dated Adrienne Bailon from 2007 to 2009. Their relationship

3
4

was even briefly featured on “Keeping Up with the Kardashians.”
89.

In one episode, Rob Kardashian is seen fighting with his then-girlfriend

5

Adrienne Bailon in front of his family. In this clip, Rob yells at Bailon for “calling off the

6

f***king wedding in India.” Rob Kardashian then violently grabbed Bailon by the arm, and

7
8
9
10
11
12
13
14
15
16

slapped her across the face, as his mother, Defendant Kris Jenner looks on. Later in the episode

17

it is revealed that Rob thought it would be funny to pretend he was slapping his girlfriend and

18

that the altercation was merely a prank. In doing so, Rob Kardashian played domestic violence

19

for laughs in this early episode of “Keeping Up with the Kardashians.”

20

90.

Then in 2014, years after the couple split, Bailon again became a target for Rob

21

and his famous family when she addressed her stint on the Kardashian’s reality show in an

22

interview with Latina magazine. During this interview Bailon said, “To be stuck with that

23

Kardashian label, that was so hurtful to me and to my career.” Bailon continued, “I probably

24

realized that too late—not that it would’ve affected my decisions in terms of who I dated, but it

25

would’ve affected my decision to appear on the show.” Bailon also claimed that she still

26

received hate from Kardashian fans, saying, “To this day, people will say, ‘You ruined Rob’s

27

life’ and I’ll think, ‘Damn, I was still playing with Barbie dolls when I met him.’”

28
35

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 91.

1

Shortly after Bailon’s interview was made public, Defendant Kim Kardashian

2

took to social media to attack Bailon and said, “Funny how [Bailon] says being with a

3

Kardashian hurt her career yet the only reason she has this article is bc she is talking about a

4

Kardashian.” Kim then said, “So sad when people try to kick my brother when he is down

5

#FamilyForever.”

6

92.

Kim and Khloe’s posts are just examples of how far the Kardashians will go to

7

bully Rob Kardashian’s ex-girlfriends—even years after they have broken-up with him.

8

VIII. REALITY TELEVISION ROYALTY
93.

9

“Keeping Up with the Kardashians” is a hit reality television program on the E!

10

Network that focuses on the Kardashian-Jenner family. The show originally starred Kim

11

Kardashian and her entire family including her mother Kris Jenner, her then-stepparent Bruce

12

Jenner, as well as her siblings Rob Kardashian, Khloe Kardashian, Kourtney Kardashian,

13

Kendall Jenner, and Kylie Jenner. In recent years, “Keeping Up with the Kardashians” stars

14

Kris Jenner and her daughters Kim, Khloe, Kourtney, Kendall and Kylie.
94.

15

The series originally debuted on October 14, 2007, making it one of the longest-

16

running reality television shows in America. The show has also catapulted Kim Kardashian

17

and her family into super stardom as the Kardashian-Jenner broad are now household names

18

and reality television royalty.

19
20
21

95.

“Keeping Up with the Kardashians” just concluded its thirteenth season in June

96.

“Keeping Up with the Kardashians” has made ratings success for the E! network

2017.

22

since its 2007 premiere. As such, the series has given rise to a host of spin-off series including,

23

“Rob & Chyna” and “The Life of Kylie.”

24

97.

On or around June 1, 2016, “Rob & Chyna” was greenlit by the E! network. The

25

series followed Rob Kardashian and Ms. White’s relationship as they prepared to welcome their

26

first child together. The network originally ordered 6 one-hour long episodes as well as a

27

special featuring the birth of the couple’s baby girl Dream Kardashian.

28
36

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 98.

1

“Rob & Chyna” originally premiered on September 11, 2016, to stellar ratings as

2

it delivered approximately 2.7 million viewers—making it E! network’s most watched

3

unscripted series debut in 2016 among its primary demographic adults 18-34.
99.

4

On information and belief, the E! network would have renewed the series for a

5

second season, which was to consist of eight episodes and was expected to air some time in

6

2017. However, in or around March 2017, the network announced that “Rob & Chyna” would

7

not film its second season.

8

IX.

KARDASHIANS INTERFERE WITH SECOND SEASON OF “ROB & CHYNA”
100.

9

On information and belief, Ms. White alleges that Defendants Kris Jenner, Kim

10

Kardashian, Khloe Kardashian, Kourtney Kardashian, Kendall Jenner, and Kylie Jenner

11

intentionally interfered with Ms. White’s Talent Agreement with the E! network. Defendants

12

also intentionally interfered with Ms. White’s prospective economic advantage in filming a

13

second season of “Rob & Chyna.”
101.

14

In or around February 2017, the E! network decided to move forward with a

15

second season of its hit show “Rob & Chyna”, despite that the couple split months prior in

16

December 2016, all necessary parties agreed to film a second season focusing on Rob and

17

Chyna’s relationship co-parenting their baby girl Dream Kardashian. Not only were the stars

18

and the network onboard to film the second season but Bunim/Murray Productions was also on

19

board with season two of one of E! network’s top-rated shows, “Rob & Chyna.”

20

///

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

///
37

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 102.

1

Further, the second season of “Rob & Chyna” was already being promoted

2

before the first season even ended. The first season of “Rob & Chyna” closed with a screen

3

grab of Ms. White, Rob, Dream and King all together and a caption that read, “New Season

4

Coming 2017.”

5
6
7
8
9
10
11
12
13
14
15
16
103.

17

On February 8, 2017, Jeffrey Fuhrman, the Senior Vice President of Business

18

Affairs at the E! network emailed Ms. White’s agent and said, “E! is seeking to increase Blac

19

Chyna’s participation on the next seasons of ‘Keeping Up with the Kardashians’ to address Rob

20

and Chyna’s storyline with the goal of bringing ‘Rob & Chyna’ back shortly thereafter.” As

21

such, the network planned to bring “Rob & Chyna” back for a second season even after the

22

couple broke-up in December 2016.
104.

23

Moreover, in or around February 2017, pre-production for the second season of

24

“Rob & Chyna” was well-underway as producers were being selected and story lines were

25

being planned as indicated in an email exchange between NBC Universal executive 10

26

Demondre Edwards and Ms. White’s entertainment attorney Walter Mosley. On February 16,

27
10

28
THE
BLOOM FIRM

The E! Network is part of NBCUniversal Cable Entertainment Group, which a subsidiary of
NBC Universal.
38
CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

2017, Demondre Edwards, who is NBC Universal’s Director of Business and Legal Affairs,

2

emailed Mosley and said, “Did you have a chance to discuss the creative of the shoot with the

3

showrunner? Just trying to see if we’re all on the same page.” It is clear from these

4

communications that the network was not only onboard with filming a second season of “Rob

5

& Chyna” but that it was already actively working on the second season when Rob

6

Kardashian’s family intentionally interfered with production on the second season.

7

105.

On information and belief, in or around February 2017, Defendants Kris Jenner,

8

Kim Kardashian, Khloe Kardashian, Kourtney Kardashian, Kendall Jenner, and Kylie Jenner

9

contacted E! network executives to demand the network not proceed with a second season of

10
11

“Rob & Chyna.”
106.

Shortly thereafter, attorneys for the network informed Ms. White and her legal

12

team that the network could not proceed with filming the second season as Rob’s mother Kris

13

Jenner and his sisters Kim Kardashian, Khloe Kardashian, Kourtney Kardashian, Kendall

14

Jenner, and Kylie Jenner demanded the second season of “Rob & Chyna” not be filmed.

15

107.

Also around this time, Bunim/Murray Productions confirmed that it was the

16

network’s current position that the reason the second season was not proceeding was indeed

17

because Kris Jenner and the Kardashian-Jenner sisters demanded it not be filmed.

18

108.

After Rob’s family interfered with Ms. White’s existing Talent Agreement with

19

E! Media Productions LLC (hereinafter “the E! network”) the E! network agreed to table

20

negotiations for the second season of “Rob & Chyna”. On February 8, 2017, the E! network

21

even sought a seven-month extension on Ms. White’s second season option, which would have

22

allowed the network until October 16, 2017 to decide whether it would pick-up “Rob & Chyna”

23

for a second season as indicated in an email from Jeffrey Fuhrman to Ms. White’s agent.

24

109.

As a result, in or around February 2017, the E! network agreed to pay Ms. White

25

to appear on four episodes of “Keeping Up with the Kardashians” at the rate she would have

26

been paid for an episode of “Rob & Chyna.” However, this agreement was always intended to

27

give the network a few months to reconvene negotiations for season two after the Kris Jenner

28

and the Kardashian sisters had time to “cool off.”
39

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

110.

At all times relevant, Rob Kardashian was in favor of filming a second season of

2

“Rob & Chyna.” In fact, Rob Kardashian was so much in favor of a second season of “Rob &

3

Chyna” that he personally contacted one of the show’s creators, Ryan Seacrest to intervene with

4

Rob’s family. Rob even contacted Jeff Jenkins and Farnaz Farjam, executive producers of both

5

“Rob & Chyna” and “Keeping Up with the Kardashians” to intervene so as to save the second

6

season. However, Rob’s efforts were to no avail.

7

111.

Then in or around April 2017, Rob Kardashian texted Ms. White to inform her

8

that he spoke to his mother and said, “Why don’t you let Chyna do her own show so Dream can

9

make some money?” Again, Rob’s efforts to convince his family otherwise as to a second

10
11

season proved unsuccessful.
112.

Despite the E! network paying Ms. White to appear on four episodes during the

12

thirteenth season of “Keeping Up with the Kardashians,” Ms. White only actually appeared on

13

one episode as Rob Kardashian’s famous family once again intervened to harm Ms. White.

14

113.

The Defendants’ intentional interference with the second season of “Rob &

15

Chyna” was reported in an article by the entertainment trade publication Variety on July 7,

16

2017—two days following Rob Kardashian’s social media attack on Ms. White.

17
18
19

114.

In this article, the trade publication confirmed that the show “had already been

taken off the network’s schedule, prior to this week’s romantic falling out.”
115.

In the Variety article, an E! network spokesperson even confirmed that the

20

decision to pull “Rob & Chyna” was not the decision of the network or the show’s stars but

21

rather Rob’s powerful family. In doing so, the network spokesperson said, “As always we

22

follow the family’s lead regarding their lives and relationships, and viewers saw firsthand as the

23

family discussed putting ‘Rob & Chyna’ on hold in an episode of ‘Keeping Up with the

24

Kardashians’ this spring.” (emphasis added.)

25

116.

The Variety article also reported that E! had not yet officially cancelled “Rob &

26

Chyna”—even in the wake of Rob’s social media rant on July 5, 2017—thus, indicating that the

27

network was still interested in pursuing a second season of “Rob & Chyna.”

28
40

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 117.

1
2

As mentioned in the Variety article, Rob Kardashian’s family made their

disapproval of a second season of “Rob & Chyna” no secret.
118.

3

In fact, an episode 11 that aired during the most recent season of “Keeping Up

4

with the Kardashians” dedicated a substantial time to the topic of whether Rob and Ms. White

5

should film a second season of “Rob & Chyna.” During this episode, Kris Jenner and her

6

daughters Kim, Khloe, Kourtney, Kendall, and Kylie all gather at a restaurant to discuss

7

whether a second season of “Rob & Chyna” should be filmed. Most notably, neither Rob nor

8

Chyna were present at this meeting where Rob’s family discussed the fate of their show “Rob &

9

Chyna.”
119.

10

In this scene, Defendant Kim Kardashian explained, “Rob and Chyna are about

11

to start filming the second season of their show. And no one feels that they should fuel this bad

12

unhealthy energy by filming another season of their show . . .”
120.

13
14

During this scene, Defendant Khloe Kardashian said, “To be honest with you,

this is such a toxic relationship and we all don’t think it’s a good idea that they film this show.”
121.

15

While dining, Defendant Kim Kardashian calls Rob on speaker phone and

16

explains, “So I am here with everyone. When we get protective over you, it’s just us saying

17

like hey, (sic) all fucking shit like this happened to all of us before.” To which Rob Kardashian

18

responded, “But I never once said or judged or tried to change the outcome of any of your guys’

19

relationships.” During this phone call, Defendant Khloe Kardashian interjects and accused Rob

20

of having his “head so far up Chyna’s ass.” At which point, Rob yells “Yo, I’m done! I’m

21

done!” and hangs up the phone on his family.
122.

22

After the phone call, Rob’s family continues to discuss whether “Rob & Chyna”

23

should film for a second season. Defendant Kris Jenner tells the table, “Do you know what Rob

24

does all day? Calls her names and says she’s a lot worse things—” Defendant Kylie Jenner

25

then interrupted her mother and asked, “So why would you want to put them on a show

26

together?”

27
11

28
THE
BLOOM FIRM

The episode in question was entitled “The Ex Files” and originally aired as episode 7 of
season 13 on April 23, 2017. The show is taped weeks or months earlier.
41
CIVIL COMPLAINT

WHITE V. KARDASHIAN

 123.

1

Defendant Kendall Jenner exclaimed, “A show should not be coming out of

2

anyone’s mouth because that is the craziest thing that I have ever heard! The fact that

3

everyone’s lives revolve around a show and to make someone happy with a show is the most

4

sad depressing thing—” Defendant Kourtney Kardashian then explained to her younger sister,

5

“But it is a job! It’s their life.” Defendant Kim Kardashian agrees, saying, “It’s a job.”
124.

6
7

show is what got him out of bed!” 12
125.

8
9
10

Defendant Kris Jenner, then points her finger at Kendall and says, “Hey! That

Later in the scene, Defendant Kim Kardashian explained, “I think Rob is trying

to hold on to the show because it is his way of holding onto Chyna and it is his way to make
Chyna happy. He is trying to please someone else and I think that it is just too much.”
126.

11

While Kim Kardashian’s interview suggests that the family is merely stepping in

12

to protect their brother from his evil ex, in reality, the Kardashian-Jenner family were up to

13

something much more nefarious. Rather than trying to protect Rob Kardashian from cameras,

14

in reality, the famous family was flexing their muscles so as to destroy Ms. White’s career so

15

that she was no longer able to compete against the Kardashian-Jenner women as an

16

entrepreneur and social media influencer.
127.

17

Moreover, Ms. White alleges on information and belief that in killing the second

18

season of “Rob & Chyna,” Defendants ensured that the E! network had room in its schedule for

19

Kylie Jenner to star in her own show, in which she heavily promoted Kylie Cosmetics, which

20

was once in direct competition with LASHED by Blac Chyna.
128.

21

Later in this episode, Defendant Kourtney Kardashian tells Scott Disick, the

22

father of her children, about the meeting and said, “So we had a meeting about Rob and Chyna

23

and just like if they should have their show or not. I mean we were just saying for the

24

wellbeing of like Rob that we don’t really think that he should have it.”
129.

25

In standing up for Rob, Scott Disick, said, “It’s not the worst thing in the world

26
27
Prior to his romantic relationship with Ms. White, Rob Kardashian spent years being
depressed and began to live reclusively as he gained a significant amount of weight.
42
12

28
THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

for him to show the world what happened and to share his side. I mean I feel like ultimately

2

like this is like really should be Rob and Chyna’s decision . . .” Defendant Kourtney

3

Kardashian responded, “I personally just don’t think like shooting season 2 of ‘Rob & Chyna’

4

is the best decision . . .”

5
6
7

130.

However, when Scott asked her if Rob wants to shoot a second season,

Defendant Kourtney Kardashian said, “Yeah.”
131.

In a later scene, Rob Kardashian explains the dynamics of his relationship with

8

Ms. White and says, “She says what she has to say to you because she’s in the heat of the

9

moment and that’s what it is. Just like I post shit on the internet when I’m in the heat of the

10

moment, she texts all her people and lets them know what’s going on in our relationship.” On

11

information and belief, in this scene, Rob Kardashian is defending his relationship to his mother

12

after he made a spectacle of their split by posting videos on Snapchat after Ms. White left him.

13

132.

Later in this “Keeping Up with the Kardashians” episode, Defendants Kim and

14

Kourtney Kardashian receive an email from Rob in which he pleads with this family to allow

15

“Rob & Chyna” to film for the second season. Defendant Kim Kardashian reads the email

16

aloud, in which Rob explained why he wanted a second season and said:

17

20

“I’m trying to work on myself, trying to grow and change and I’m looking to
be the man you all are proud of. Part of that is working through my issues
with Chyna. I love Chyna and I want to be able to tell my daughter that I did
everything I could to make it work with her mother. Most of my confidence
comes from me having this show everyday. I want a second season of ‘Rob
& Chyna.’ I wanna use this show to make myself stronger.”

21

133.

18
19

In the last scene of the episode, Rob sits down with his sisters, Defendants Kim

22

and Kourtney Kardashian to explain face-to-face why he wanted to have a second season of

23

“Rob & Chyna.” During this meeting Rob said, “I was doing good when we were filming,

24

obviously. Things were great this year and then the end of the year just like things ended on a

25

whatever note.” Rob then said, “Like you can’t tell someone how to live their lives, they just

26

have to figure it out themselves.” While Defendant Kim Kardashian tells Rob, “ultimately, it is

27

up to you.”

28
43

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 134.

1

In reality, Rob Kardashian’s mother and sisters did not allow him to decide the

2

fate of the second season of “Rob & Chyna”—nor did they allow Ms. White to decide. Rather,

3

Defendants Kris Jenner, Kim Kardashian, Khloe Kardashian, Kourtney Kardashian, Kendall

4

Jenner, and Kylie Jenner invoked their power and influence over the E! network to kill the

5

second season of “Rob & Chyna.” They did so despite the fact that the stars of the show, the

6

production company, and the network were all on board with a second season of the highly

7

rated reality spinoff series.

8

X.

THE KARDASHIAN-JENNER FAMILY CONTINUE TO DEFAME MS. WHITE
135.

9

Ms. White alleges on information and belief that Rob Kardashian and his family

10

continue to defame her in the press. As recent as September 15, 2017, Rob Kardashian, his

11

family, and/or their agents leaked a false and defamatory story about Ms. White to the press. 13
136.

12

Ms. White alleges that Rob Kardashian and his family published the false

13

statements in this story to further damage her reputation. In this story, it was falsely stated that

14

Rob Kardashian received more than fifty percent custody of Dream and that Ms. White “wanted

15

north of $50k” a month in child support.
137.

16

Further, these sources falsely implied that Ms. White was a bad mother when

17

they said, “[Ms. White] left Dream at home this weekend while she left to party, and [Rob

18

Kardashian] wants to make sure there are enough nannies to protect [Dream].” The truth is that

19

Ms. White left Dream with a nanny while she was working at a paid public appearance. Rob

20

Kardashian made similar accusations against Ms. White through his attorneys during

21

confidential settlement negotiations for their family law case.
138.

22

Accordingly, Rob Kardashian and his famous family continue to defame Ms.

23

White even after his vicious social media tirade on July 5, 2017.

24

///

25

///

26
27
28
THE
BLOOM FIRM

13

On information and belief, these sources were Defendants and/or their respective agents, as
the information revealed was a part of confidential settlement discussions taking place in their
family law case. Accordingly, Defendant Rob Kardashian and his family were the only people
to know the true details of Rob Kardashian and Ms. White’s custody agreement.
44
CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

FIRST CAUSE OF ACTION

2

(ASSAULT)

3

(as Against Defendant Rob Kardashian)

4
5
6

139.

Ms. White restates and incorporates by reference, as though fully set forth

herein, the allegations contained in each of the paragraphs above.
140.

On or around April 8, 2017, Rob Kardashian intended to cause and did cause

7

Ms. White to suffer apprehension of an immediate harmful contact to her person when he

8

grabbed her phone from her and violently knocked her to the ground in the presence of her 4-

9

year-old son.

10

141.

Ms. White did not consent to Rob Kardashian’s objectively unreasonable acts of

11

yelling at her, aggressively grabbing her phone out of her hand and violently knocking her to

12

the ground.

13

142.

By engaging in the conduct as hereinabove alleged, Defendant Rob Kardashian

14

acted with malice, fraud, and oppression and/or conscious disregard of Ms. White’s rights, and

15

well-being, and intended to subject Ms. White to unjust hardship thereby warranting an

16

assessment of punitive damages in an amount sufficient to punish Defendant and deter others

17

from engaging in similar conduct.

18

143.

As a direct and proximate result of Rob Kardashian’s conduct on or around April

19

8, 2017, as alleged herein, Ms. White suffered, and will continue to suffer the damages herein

20

mentioned, in an amount according to proof at trial.

21

SECOND CAUSE OF ACTION

22

(BATTERY)

23

(as Against Defendant Rob Kardashian)

24
25
26

144.

Ms. White restates and incorporates by reference, as though fully set forth

herein, the allegations contained in each of the paragraphs above.
145.

On or around April 8, 2017, Rob Kardashian touched or caused Ms. White to be

27

touched with the intent to harm or offend her when he aggressively grabbed her phone from her

28

hand and violently knocked her to the ground.
45

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

146.

At all times relevant, Ms. White did not consent to Rob Kardashian’s conduct in

2

aggressively grabbing her phone and violently knocking her to the ground in the presence of her

3

4-year-old son.

4
5
6

147.

As a result of Mr. Kardashian’s harmful and offensive touching, Ms. White was

injured and suffered difficulty walking for days following the attack.
148.

By engaging in the conduct as hereinabove alleged, Defendant Rob Kardashian

7

acted with malice, fraud, and oppression and/or conscious disregard of Ms. White’s rights, and

8

well-being, and intended to subject Ms. White to unjust hardship thereby warranting an

9

assessment of punitive damages in an amount sufficient to punish Defendant and deter others

10
11

from engaging in similar conduct.
149.

As a direct and proximate result of Rob Kardashian’s conduct, as alleged herein,

12

Ms. White has suffered, and will continue to suffer the damages herein mentioned, in an

13

amount according to proof at trial.

14

THIRD CAUSE OF ACTION

15

(VIOLATION OF CAL. CIV. CODE § 1708.85—DISTRIBUTION OF PRIVATE

16

SEXUALLY EXPLICIT MATERIALS)

17

(as Against Defendant Rob Kardashian)

18
19
20

150.

Ms. White restates and incorporates by reference, as though fully set forth

herein, the allegations contained in each of the paragraphs above.
151.

Rob Kardashian violated Ms. White’s right to privacy by intentionally

21

distributing private sexually explicit materials of Ms. White when he posted her private nude

22

photographs on multiple social media platforms on or around July 5, 2017.

23
24
25
26

152.

At all times relevant, Ms. White did not consent to the Rob Kardashian’s

distribution of her private nude photos that revealed her genitals, buttocks, and nipples.
153.

Rob Kardashian knew that Ms. White had a reasonable expectation that her nude

photos would remain private.

27
28
46

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

154.

The nude photos of Ms. White that Rob Kardashian distributed online on or

2

around July 5, 2017, exposed Ms. White’s intimate body parts, including her genitals, buttocks,

3

and nipples.

4

155.

Rob Kardashian’s distribution of Ms. White’s private nude photos caused Ms.

5

White to suffer emotional distress, harm to her reputation, including shame, mortification and

6

hurt feelings as well as harm to her property, business, profession, and occupation.

7
8
9

156.

Defendant’s distribution of Ms. White’s nude photos online was a substantial

factor in causing Ms. White’s harm.
157.

By engaging in the conduct as hereinabove alleged, Defendant Rob Kardashian

10

acted with malice, fraud, and oppression and/or conscious disregard of Ms. White’s rights, and

11

well-being, and intended to subject Ms. White to unjust hardship thereby warranting an

12

assessment of punitive damages in an amount sufficient to punish Defendant and deter others

13

from engaging in similar conduct.

14

158.

As a direct and proximate result of Defendant Rob Kardashian’s conduct, as

15

alleged herein, Ms. White has suffered, and will continue to suffer the damages herein

16

mentioned, in an amount according to proof at trial.

17

FOURTH CAUSE OF ACTION

18

(VIOLATION OF CAL. CIV. CODE § 1708.6—DOMESTIC VIOLENCE)

19

(as Against Defendant Rob Kardashian)

20
21
22

159.

Ms. White restates and incorporates by reference, as though fully set forth

herein, the allegations contained in each of the paragraphs above.
160.

Rob Kardashian intentionally and recklessly caused bodily injury or attempted to

23

cause bodily injury to Ms. White, or placed Ms. White in reasonable apprehension of imminent

24

bodily harm.

25
26

161.

The infliction of such injury to Ms. White, as set forth above, occurred after Ms.

White ended her intimate relationship with Rob Kardashian.

27
28
47

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

162.

On information and belief, Ms. White alleges that unless Rob Kardashian is

2

restrained by permanent injunction he will continue to harass, attack, threaten, assault, molest,

3

disturb the peace of Ms. White, and cause her further injury and harm.

4

163.

Ms. White has no adequate remedy at law because monetary damages alone,

5

which may compensate for past violence or threats of violence, will not afford adequate relief

6

for the fear, humiliation, and risk of serious injury or death that a continuation of Rob

7

Kardashian’s conduct in denial of Ms. White’s rights will cause.

8
9

164.

By engaging in the conduct as hereinabove alleged, Defendant Rob Kardashian

acted with malice, fraud, and oppression and/or conscious disregard of Ms. White’s rights, and

10

well-being, and intended to subject Ms. White to unjust hardship thereby warranting an

11

assessment of punitive damages in an amount sufficient to punish Defendant and deter others

12

from engaging in similar conduct.

13

165.

As a direct and proximate result of Defendant Rob Kardashian’s conduct, as

14

alleged herein, Ms. White has suffered, and will continue to suffer the damages herein

15

mentioned, in an amount according to proof, including attorneys’ fees and costs.

16

FIFTH CAUSE OF ACTION

17

(VIOLATION OF CAL. CODE CIV PROC. § 527.6—CIVIL HARASSMENT)

18

(as Against Defendant Rob Kardashian)

19
20
21

166.

Ms. White restates and incorporates by reference, as though fully set forth

herein, the allegations contained in each of the paragraphs above.
167.

Rob Kardashian’s harassment of Ms. White, as described above, was a knowing

22

and willful course of conduct directed specifically at Ms. White that seriously alarmed,

23

annoyed, or harassed Ms. White and that served no legitimate purpose, thus constituting civil

24

harassment under California Code of Civil Procedure section 527.6.

25

168.

Rob Kardashian’s course of conduct in relentlessly texting, emailing, and calling

26

Ms. White in an effort to harass her would cause a reasonable person to suffer substantial

27

emotional distress, and actually did cause Ms. White to suffer substantial emotional distress.

28
48

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1
2
3
4
5

169.

Rob Kardashian’s constant verbal abuse and harassment over text, email, and

phone were a substantial factor in causing Ms. White’s severe emotional distress.
170.

As a result of Defendant’s harassment, Ms. White has suffered emotional

distress, ridicule, as well as loss of income and career benefits.
171.

Rob Kardashian’s conduct will continue to cause great and irreparable injury to

6

Ms. White, who has no adequate remedy at law for the injuries that she is currently suffering

7

and will continue to suffer as a result of Defendant’s harassment. Accordingly, injunctive relief

8

is necessary and proper.

9

172.

Pursuant to California Code of Civil Procedure section 627.6(r), Ms. White is

10

entitled to an award of the attorney’s fees she incurs in prosecuting this action and seeking an

11

injunction pursuant to Section 527.6.

12

173.

As a direct and proximate result of Rob Kardashian’s conduct, as alleged herein,

13

Ms. White has suffered, and will continue to suffer the damages herein mentioned, in an

14

amount according to proof, including attorneys’ fees and costs.

15

SIXTH CAUSE OF ACTION

16

(INTRUSION INTO PRIVATE AFFAIRS)

17

(as Against Defendant Rob Kardashian)

18
19
20

174.

Ms. White restates and incorporates by reference, as though fully set forth

herein, the allegations contained in each of the paragraphs above.
175.

Rob Kardashian violated Ms. White’s right to privacy on or around July 5, 2017,

21

when he posted several private nude photos of her and publicized Ms. White’s personal medical

22

information, including surgeries she allegedly underwent.

23

176.

At all times relevant, Ms. White had a reasonable expectation of privacy in her

24

private nude photos including photos of her genitals, buttocks, and nipples. Ms. White also had

25

a reasonable expectation of privacy in her private photos taken while she was preparing for

26

surgery, and her personal medical information, including surgeries she allegedly underwent.

27
28
49

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 1

177.

Rob Kardashian intentionally intruded into Ms. White’s private affairs when he

2

posted private nude photos of Ms. White, including photos of her genitals, buttocks, and nipples

3

on or around July 5, 2017.

4

178.

Defendant also intentionally intruded into Ms. White’s private affairs by

5

publishing private photos of Ms. White while she was preparing for surgery and revealing

6

personal medical information about Ms. White on or around July 5, 2017.

7

179.

Rob Kardashian’s intrusion would be highly offensive to a reasonable person in

8

Ms. White’s position as he published Ms. White’s private nude photos and personal medical

9

information in an effort to destroy Ms. White’s reputation.

10

180.

Upon information and belief, Rob Kardashian’s wrongful conduct was a

11

substantial factor in causing Ms. White’s harm, including, but not limited to, harm to Ms.

12

White’s trade, profession, and/or occupation, and harm to Ms. White’s reputation.

13

181.

By engaging in the conduct as hereinabove alleged, Defendant Rob Kardashian

14

acted with malice, fraud, and oppression and/or conscious disregard of Ms. White’s rights, and

15

well-being, and intended to subject Ms. White to unjust hardship thereby warranting an

16

assessment of punitive damages in an amount sufficient to punish Defendant and deter others

17

from engaging in similar conduct.

18

182.

As a direct and proximate result of Rob Kardashian’s conduct, as alleged herein,

19

Ms. White has suffered, and will continue to suffer the damages herein mentioned, in an

20

amount according to proof at trial.

21

SEVENTH CAUSE OF ACTION

22

(FALSE LIGHT)

23

(as Against All Defendants)

24
25
26
27

183.

Ms. White restates and incorporates by reference, as though fully set forth

herein, the allegations contained in each of the paragraphs above.
184.

Rob Kardashian’s social media rant on or around July 5, 2017, contain numerous

false implications about Ms. White, including without limitation:

28
50

THE
BLOOM FIRM

CIVIL COMPLAINT

WHITE V. KARDASHIAN

 a.

1

that Ms. White and Rob Kardashian were in a romantic relationship as
late as July 2017;

2
3

b.

that Ms. White had recently cheated on Rob Kardashian;

4

c.

that Ms. White had her “baby out of spite”; and

5

d.

that Ms. White withheld her daughter from seeing Rob Kardashian.

6

185.

Further, Defendants made false statements about Ms. White, including that she

7

“left Dream at home this weekend while she left to party, and [Rob Kardashian] wants to make

8

sure there are enough nannies to protect [Dream]” on or around September 15, 2017.

9

186.

The unfair and inaccurate depictions of Ms. White, and the false impressions and

10

implications created by Rob Kardashian’s social media rant on or around July 5, 2017 and

11

Defendants’ subsequent conduct, are highly offensive to a reasonable person of ordinary

12

sensibilities in Ms. White’s position.

13

187.

Upon information and belief, members of the community understood that

14

Defendants’ statements were about Ms. White as the statements were about, concerning, and

15

mentioned Ms. White expressly. These false statements about Ms. White had a natural

16

tendency to injure Ms. White’s reputation in the entertainment industry in which she works, and

17

with the public worldwide.

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188.

Defendants published these false statements about Ms. White knowing that they

19

contained unfair and inaccurate depictions of Ms. White, and false implications that would

20

damage Ms. White’s reputation in the community.

21

189.

Upon information and belief, Defendants’ wrongful conduct was a substantial

22

factor in causing Ms. White’s harm, including but not limited to harm to Ms. White’s trade,

23

profession, and/or occupation, and harm to Ms. White’s reputation.

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190.

As a direct and proximate result of the above-described statements and

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depictions, Ms. White has suffered and will continue to suffer emotional distress, loss to her

26

reputation, shame, mortification, and hurt feelings, and has been, and continues to be,

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embarrassed and humiliated by the false statements and implications and reasonable fear that

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she will be shunned, avoided, and subjected to ridicule.
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191.

By engaging in the conduct as hereinabove alleged, Defendants acted with

2

malice, fraud, and oppression and/or conscious disregard of Ms. White’s rights, and well-being,

3

and intended to subject Ms. White to unjust hardship thereby warranting an assessment of

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punitive damages in an amount sufficient to punish Defendants and deter others from engaging

5

in similar conduct.

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192.

As a direct and proximate result of Defendants’ conduct, as alleged herein, Ms.

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White has suffered, and will continue to suffer the damages herein mentioned, in an amount

8

according to proof at trial.

9

EIGHTH CAUSE OF ACTION

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(PUBLIC DISCLOSURE OF PRIVATE FACTS)

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(as Against Defendant Rob Kardashian)

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193.

Ms. White restates and incorporates by reference, as though fully set forth

herein, the allegations contained in each of the paragraphs above.
194.

Rob Kardashian violated Ms. White’s right to privacy by posting several private

nude photos of Ms. White on multiple social media platforms on or around July 5, 2017.
195.

Moreover, on or around July 5, 2017, Rob Kardashian also published private

17

medical information about Ms. White and posted photos of her while she was preparing for

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surgery.

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196.

Rob Kardashian publicized private information concerning Ms. White to

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millions of people on multiple social media platforms and the world when he publicly attacked

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Ms. White during his vile social media rant on or around July 5, 2017.

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197.

A reasonable person in Ms. White’s position would consider the publicity of her

private nude photos and personal medical information highly offensive.
198.

At all times relevant, Rob Kardashian did not have Ms. White’s consent to post

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her private nude photos nor her personal medical information including, but not limited to, any

26

previous surgeries she may have undergone.

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199.

Rob Kardashian knew, or acted with reckless disregard of the fact, that a

2

reasonable person in Ms. White’s position would consider the publicity of her private nude

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photos and personal medical information highly offensive.

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200.

The private nude photos and personal medical information of Ms. White that

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Rob Kardashian posted on social media was not of legitimate public concern as such

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information was entirely devoid of all social value.

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201.

As a direct and proximate result of Rob Kardashian’s wrongful conduct, Ms.

8

White was harmed.

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202.

Rob Kardashian’s conduct in publicizing Ms. White’s private nude photos and

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personal medical information was a substantial factor in causing Ms. White’s harm, including

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emotional distress, harm to her reputation, and harm to her property, business, profession, or

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occupation.

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203.

By engaging in the conduct as hereinabove alleged, Defendant Rob Kardashian

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acted with malice, fraud, and oppression and/or conscious disregard of Ms. White’s rights, and

15

well-being, and intended to subject Ms. White to unjust hardship thereby warranting an

16

assessment of punitive damages in an amount sufficient to punish Defendant and deter others

17

from engaging in similar conduct.

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204.

As a direct and proximate result of Defendants’ conduct, as alleged herein, Ms.

19

White has suffered, and will continue to suffer the damages herein mentioned, in an amount

20

according to proof at trial.

21

NINTH CAUSE OF ACTION

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(DEFAMATION: LIBEL)

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(as Against Defendant Robert Kardashian)

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26
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205.

Ms. White restates and incorporates by reference, as though fully set forth

herein, the allegations contained in each of the paragraphs above.
206.

On or around July 5, 2017, Rob Kardashian made numerous false statements of

fact about Ms. White to millions of people other than Ms. White on various social media

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 1

platforms. Rob Kardashian falsely announced to his millions of social media followers that Ms.

2

White cheated on Defendant, had her “baby out of spite.”

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4
5

207.

On or around July 5, 2017, Rob Kardashian also falsely implied that he and Ms.

White were in a relationship as late as July 2017 and posted that she “got caught cheating.”
208.

On or around July 5, 2017, Rob Kardashian also falsely claimed that Ms. White

6

kept him from seeing their 8-month-old daughter and said, “bring Dream back to her Dad

7

please . . . she has the guard gate not letting me in the gate either. I just miss baby Dream.” In

8

doing so, Defendant created a meme entitled “How The Chyna stole Christmas!” which

9

Defendant designed to falsely state that Ms. White was withholding their daughter from seeing

10

her father—despite the fact that Rob Kardashian wrongfully withheld Dream from her mother

11

on July 6, 2017 when she was originally scheduled to be returned to Ms. White. In reality, Rob

12

Kardashian did not return the baby to Ms. White until July 7, 2017.

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209.

At all times relevant, Rob Kardashian’s social media posts made on or around

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July 5, 2017, were false and exposed Ms. White to hatred, contempt, ridicule, or shame. Rob

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Kardashian’s false statements also caused her to be shunned or despised by those who hear

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and/or viewed such comments on social media and the various news publications that continue

17

repost Defendant’s false and vile statements about Ms. White made on or around July 5, 2017.

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210.

Rob Kardashian also falsely implied that he was currently in a romantic

19

relationship with Ms. White on or around July 5, 2017. However, Rob Kardashian and Ms.

20

White have not been a couple since December 2016, despite tabloid speculation otherwise.

21

During his social media rant, Defendant intentionally deceived his millions of social media

22

followers and the world when he falsely implied he and Ms. White had been a couple up until

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July 5, 2017, so as to further fuel public hatred of Ms. White.

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211.

Further, Rob Kardashian, his family, and/or their respective agents made false

25

statements about Ms. White to the press, including that she “left Dream at home this weekend

26

while she left to party, and [Rob Kardashian] wants to make sure there are enough nannies to

27

protect [Dream].”

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2
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212.

Defendants either knew that his written statements were false or they failed to

use reasonable care to determine the truth or falsity of his statements.
213.

Defendants’ false statements caused Ms. White to suffer emotional distress,

harm to her reputation, and harm to her property, business, profession, or occupation.
214.

By engaging in the conduct as hereinabove alleged, Defendant Rob Kardashian

6

acted with malice, fraud, and oppression and/or conscious disregard of Ms. White’s rights, and

7

well-being, and intended to subject Ms. White to unjust hardship thereby warranting an

8

assessment of punitive damages in an amount sufficient to punish Defendant and deter others

9

from engaging in similar conduct.

10

215.

As a direct and proximate result of Defendants’ conduct, as alleged herein, Ms.

11

White has suffered, and will continue to suffer the damages herein mentioned, in an amount

12

according to proof at trial.

13

TENTH CAUSE OF ACTION

14

(INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS)

15

(as Against Defendants Kris Jenner, Kim Kardashian, Khloe Kardashian, Kourtney

16

Kardashian, Kendall Jenner, and Kylie Jenner)

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18
19

216.

Ms. White restates and incorporates by reference, as though fully set forth

herein, the allegations contained in each of the paragraphs above.
217.

Beginning on May 26, 2016, Ms. White had a valid Talent Agreement with E!

20

Media Productions, LLC, to star in the series “Rob & Chyna” with her then-fiancé Rob

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Kardashian.

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218.

At all times relevant, Defendants Kris Jenner, Kim Kardashian, Khloe

23

Kardashian, Kourtney Kardashian, Kendall Jenner, and Kylie Jenner (hereinafter collectively

24

“Defendants”) knew of the existence of a valid Talent Agreement between Ms. White and E!

25

Media Productions, LLC (hereinafter “the E! Network”) as alleged herein.

26

219.

However, despite their knowledge of Ms. White’s Talent Agreement with the E!

27

Network, in or around February or March 2017, Defendants intentionally interfered with the

28

Talent Agreement between the E! Network and Ms. White. During Ms. White and Rob
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Kardashian’s ongoing negotiations with these third parties regarding a second season of their hit

2

television show “Rob & Chyna,” the Defendants demanded that the E! network not renew the

3

hit show for a second season. As a result of Defendants’ intentional interference with Ms.

4

White’s contractual relationship with E! Media Productions, the network had no choice but to

5

shut down production on the second season of “Rob & Chyna.”

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7
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220.

Defendants’ conduct alleged herein prevented performance and/or made

performance of Ms. White’s Talent Agreement more difficult.
221.

On information and belief, Ms. White alleges that Defendants intentionally

interfered with Ms. White’s Talent Agreement with the E! network.
222.

After Defendants’ intentional interference in demanding the network not renew

the Talent Agreement, Ms. White was harmed personally, professionally, and financially.
223.

Defendants’ conduct herein alleged was a substantial factor in causing Ms.

White’s harm.
224.

By engaging in the conduct as hereinabove alleged, Defendants acted with

15

malice, fraud, and oppression and/or conscious disregard of Ms. White’s rights, and well-being,

16

and intended to subject Ms. White to unjust hardship thereby warranting an assessment of

17

punitive damages in an amount sufficient to punish Defendants and deter others from engaging

18

in similar conduct.

19

225.

As a direct and proximate result of Defendants Kris Jenner, Kim Kardashian,

20

Khloe Kardashian, Kourtney Kardashian, Kendall Jenner, and Kylie Jenner’s conduct, as

21

alleged herein, Ms. White has suffered, and will continue to suffer the damages herein

22

mentioned, in an amount according to proof at trial.

23

ELEVENTH CAUSE OF ACTION

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(INTENTIONAL INTERFERENCE WITH PROSPECTIVE ECONOMIC

25

ADVANTAGE)

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(as Against All Defendants)

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28
THE
BLOOM FIRM

226.

Ms. White restates and incorporates by reference, as though fully set forth

herein, the allegations contained in each of the paragraphs above.
56
CIVIL COMPLAINT

WHITE V. KARDASHIAN

 227.

1

On information and belief, Ms. White alleges that Defendants Kris Jenner, Kim

2

Kardashian, Khloe Kardashian, Kourtney Kardashian, Kendall Jenner, and Kylie Jenner

3

intentionally interfered with an economic relationship between Ms. White and the E! network,

4

E! Media Productions, LLC, and Bunim/Murray Productions in or around February or March

5

2017.

6

228.

Prior to engaging in the aforementioned conduct, Defendants were fully aware

7

that Ms. White had business relationships with the E! network, E! Media Productions, LLC, and

8

Bunim/Murray Productions, which were very likely to result in economically-advantageous

9

relationships between Ms. White, the E! network, E! Media Productions, LLC, and

10
11

Bunim/Murray Productions.
229.

Defendants engaged in the conduct alleged above with the intent of interfering

12

with and/or destroying the economically-advantageous relationships between Ms. White, on the

13

one hand, and the E! network, E! Media Productions, LLC, and Bunim/Murray Productions, on

14

the other hand, and to make those relationships less financially lucrative for Ms. White.

15

230.

Defendants’ conduct was independently wrongful because they unlawfully

16

defamed Ms. White and/or wrongfully withheld their consent for the E! network to proceed

17

with the second season of “Rob & Chyna” in order to destroy Ms. White’s career. Defendants

18

did so in order to ensure that Ms. White was unable to compete against the Kardashian-Jenner

19

women as an entrepreneur and social media influencer with television exposure. During Ms.

20

White and Rob Kardashian’s ongoing negotiations with these third parties regarding a second

21

season of their hit television show “Rob & Chyna,” the Defendants expressly demanded the E!

22

network not renew the hit show for a second season.

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24
25

231.

As a result of Defendants’ intentional interference, production on the second

season of “Rob & Chyna” was shut down even though filming had already started.
232.

At all times relevant, Ms. White, Rob Kardashian, as well as the E! network, E!

26

Media Productions, LLC, and Bunim/Murray Productions agreed to move forward with

27

production on a second season of “Rob & Chyna.” In fact, during negotiations for the first

28

amendment to Ms. White’s talent agreement with E! Media Productions, lawyers told Ms.
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White and her legal team that it was solely because Defendants Kris Jenner, Kim Kardashian,

2

Khloe Kardashian, Kourtney Kardashian, Kendall Jenner, and Kylie Jenner requested that the

3

network not proceed with the second season that the network had to put a hold on production.

4

233.

Moreover, his during vicious social media tirade, Defendant Rob Kardashian

5

intentionally interfered with Ms. White’s prospective economic advantage as a well-known

6

social media influencer. When Rob Kardashian falsely accused Ms. White of undergoing

7

weight loss surgery to lose weight after her pregnancy, he intentionally interfered with Ms.

8

White’s professional relationships with multiple health, wellness, fitness, and diet companies

9

that pay her to endorse products such as detox teas and waist trainers.

10

234.

By Defendants engaging in the conduct alleged herein, they intended to disrupt

11

Ms. White’s relationship with said third parties and/or knew that disruption of Ms. White’s

12

relationship with said third parties was certain and/or substantially certain to occur.

13
14
15
16
17

235.

As a result of Defendants’ conduct, Ms. White’s relationship with said third

parties was disrupted.
236.

Ms. White suffered personal, professional, and financial harm as a result of

Defendants’ intentional interference with her prospective economic advantage.
237.

Accordingly, Defendants’ conduct as alleged herein was purposeful and

18

intentional and was engaged in for the purposes of depriving Ms. White of property or legal

19

rights or otherwise causing injury, and was despicable conduct that subjected Ms. White to

20

cruel and unjust hardship in conscious disregard of its rights, and was performed with fraud,

21

oppression or malice so as to justify an award of exemplary or punitive damages against

22

Defendants in an amount according to proof at trial.

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24
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26
27
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CIVIL COMPLAINT

WHITE V. KARDASHIAN

 PRAYER FOR RELIEF

1
2

A.

For general and economic damages according to proof at trial;

3

B.

For pre-judgment and post-judgment interest according to law;

4

C.

For costs of suit and attorneys’ fees to the fullest extent permitted by law;

5

D.

For punitive and exemplary damages; and

6

E.

For such other and further relief as the Court may deem proper.

7
DATED: October 17, 2017

Respectfully submitted,

8
THE BLOOM FIRM

9

By: Lisa Bloom
Lisa Bloom
A. Douglas Mastroanni
Vanessa Hooker
Attorneys for Plaintiff ANGELA WHITE

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