Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 1 of 181 Page ID #:1 1 BRAD D. BRIAN (State Bar No. 79001) brad.brian@mto.com 2 MICHAEL R. DOYEN (State Bar No. 119687) michael.doyen@mto.com 3 BETHANY W. KRISTOVICH (State Bar No. 241891) bethany.kristovich@mto.com 4 MUNGER, TOLLES & OLSON LLP 350 South Grand Avenue 5 Fiftieth Floor Los Angeles, California 90071-3426 6 Telephone: (213) 683-9100 Facsimile: (213) 687-3702 7 8 Attorneys for Plaintiffs MGM RESORTS INTERNATIONAL, MANDALAY 9 RESORT GROUP, MANDALAY BAY, LLC , MGM RESORTS FESTIVAL 10 GROUNDS, LLC, and MGM RESORTS VENUE MANAGEMENT, LLC 11 12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 14 15 MGM RESORTS INTERNATIONAL, MANDALAY RESORT GROUP, 16 MANDALAY BAY, LLC, MGM RESORTS FESTIVAL GROUNDS, 17 LLC, MGM RESORTS VENUE MANAGEMENT, LLC 18 Plaintiffs, 19 vs. 20 DAVID AASE; GARY AASE; MARK 21 ABRAHAM; ANDREA ABRAMS; DANIEL ABRAMS; LUKE ADAM; 22 ROBERT AGUILAR; GLORIA AGUIRRE; BRIAN AHLERS; ESTATE 23 OF HANNAH AHLERS; MARCO ALBERTINI; RENEE ALCALA; 24 ERNESTO ALFARO; TENESHA ALFARO; SARA ALLEGRO; ETTA 25 ALLEN; LEANNE ALTAMIRANO; RUBEN ALULEMA; ALEX 26 ALVAREZ; DANIEL EARL ALVAREZ; JOANNA ALVAREZ; 27 LINDSEY ALVAREZ; DANIELLE AMBROSE; ALETHA ANDERSON; 28 NATALIE ANDERSON; REBECCA Case No. COMPLAINT FOR DECLARATORY RELIEF 39245596.3 COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 2 of 181 Page ID #:2 1 ANN ANDERSON; RYAN ANDERSON; SHANNON 2 ANDERSON; JENNIFER APARICIO; BRENDEN ARAUJO; CASSIE 3 ARDITO; RICHARD ARDITO; JESUS ASTUA; LISA AWALT; D.B., A 4 MINOR; CODI BABCOCK; CHEYENE BACON-MERIWEATHER; 5 CHRISTOPHER BADOREK; TRACEY BAKER; SHANNON BALAS; 6 TIFFANY BALL; MARY BANTA; TED BANTA; JASON BANVILLE; TEGAN 7 BANVILLE; JASMINE BARBUSCA; ESTATE OF CARRIE BARNETTE; 8 TINELLA BARRANCO; RONALD A. BARRERAS; DONOVAN BARTHEL; 9 MONIQUE D. BARTHEL; COURTNEY BEAN; BRAD BEAUCHAMP; DAWN 10 BEAUCHAMP; ALEISA BEBEE; ASHLEY BECKER; SEAN BEESON; 11 JONATHON BELL; ANNALISE BELMARES; MEGHAN BELMARES; 12 JONATHAN BELTRAN; DANIEL R. BEST; CARLY BETZLER; TAYLOR 13 BLAISER; JANNETTE BLAKE; PAULA BLAKELEY; JODI 14 BOATWOOD; AMANDA BOBB; DYLAN BODEN; EMILY BODEN; 15 JOY BODEN; MADDISON BODEN; MARK BODEN; CRYSTAL BOLKE; 16 DIANELLA BONO; MAUREEN BONTE; NICOLE BONTEMPO; PAUL 17 BOONE; KURTIS ANTHONY BOWERS; ESTATE OF CANDICE 18 BOWERS; K.L.A., A MINOR; A.R.B. , A MINOR; VEDAMAY BRADFORD; 19 MICHAEL BRADLEY; CINDY BRADSHAW; ROBERT BRADSHAW; 20 LAUREN BRADY; DAVID BRAKE; STEVEE BRANCATO; JAMES 21 BRIGHTLY; MAILYS BRIGHTLY; EDWARD BROWN; ERIKA BROWN; 22 RONDA BROWN; STEPHANIE BROWN; STACEY BROWN-FUSANO; 23 TAYLER BRUNNER; JOHN BUI; TREANESHA LASHONDA BULLION; 24 TERRY BURK; ANDREA BUSTAMANTE; GABRIELLA 25 BUSTAMANTE; HECTOR CABALLERO; HEATHER L. CAIN; 26 JENNIFER CAMPAS; JENNIFER L. CAMPBELL; LYNZEE CAMPBELL; 27 JULIA CAMPOS; KAREN CANADA; INGRID CANELO; RENEE CANELO; 28 MARY CANICH; EMILY CANTRELL; 39245596.3 COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 3 of 181 Page ID #:3 1 BRITTNIE NICOLE CARDENAS; JESSICA CAREY; KATE CARLIN; 2 KARI CARLSTROM; ALEXANDER CARRIAGA; KIMBERLY CARRIAGA; 3 MATTHEW CARRILLO; IAN CARTER; ELIZABETH A. 4 CARVALHO; CONNOR CASAREZ; VANESSA CASE; MICHELLE ANN 5 CASHMAN; CARLEY CASS; GUS CASTILLA; ESTATE OF ANDREA 6 CASTILLA; MARISSA CASTLE; REBECCA CASTRO; ANGELA 7 CATURA; CHRISTOPHER CAYWOOD; KASANDRA 8 CAYWOOD; KERI CESARIO; ROBERT CESARIO; LAUREN 9 CHAGOLLA; TAMMY J. CHAMBERS; DAVID CHATTERTON; MARIE 10 CHATTERTON; VERONICA CHAVEZ; KRISTI CHRISTENSEN; 11 FABIOLA CINTRON; ROGER CINTRON; ALISA CLAWSON; KARA 12 CLEMENT; LARISSA COBURN; DONNA COCHRANE; RICHARD D. 13 COE; DAVID COLE; JOSEPH COLE; DENNIS NEAL COLEMAN; 14 RONALDO CONCEPCION; KATHLEEN CONTI; MELISSA 15 CONTRI; CHRISTA CONWAY; WILLIAM COOK; WENDY COOPER; 16 PATRICIA COPE; JESSE CORTEZ; LISA CORTEZ; DOUGLAS CORUM; 17 TYLER CRAIG; BRENDA CRANE; BRITTANI CRAWFORD; ANTHONY 18 M. CRESTA; ANTHONY CRISCI; PATRICIA CRISS; KIRA M. CROSS; 19 JOY M. CRUZ; JENNIFER CUEVAS; ADRIANNA CULLER; MARISSA J. 20 CURRIE; TAMMY CURTIS; NICOLE CUSICK; ROBERT CUSICK; ESTATE 21 OF DERRICK D. TAYLOR; ANDREW DAHRING; NANCY DAHRING; LISA 22 DANCEL; LISA MARIE DANIELS; PRITESH DAVDA; KYLE DAVID; 23 JESSICA DAVIES; AMANDA DAVIS; ELLEN DAVIS; DEBORAH 24 DAWKINS; DEANNA DAWSON; LORI DAWSON; THOMAS DAY SR.; 25 ESTATE OF THOMAS DAY; KELSEY DAY; NOLAN DAY; WHITNEY DAY; 26 DIANA DE LA MAZA; ROLAND DE LA MAZA; CYNTHIA DEARING; 27 TAMARA DELAMETER; AMY DELAPLANE; ALEJANDRA 28 DELAROSA; BRETT DELAURA; 39245596.3 COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 4 of 181 Page ID #:4 1 KORTNEY DELAWAY; NICOLE DELGADILLO; LARRY DELGADO; 2 DANIELLE DELIRA; NICOLE DESARACHO; ROBERT DI NONNO; 3 MIKAELA DIAZ; REGINA DIERINGER; RYAN DIERINGER; 4 DIANA J. DIMITRUK; VANESSA DIPOLITO; LAURA DIXON; ROBYN 5 DOBBS; DANIEL DOMINGUEZ; KARIN DONIS; ELYSE DONNELLY; 6 KYLE L. DONNER; WENDY A. DORMER; ALLISON DORR; JESSICA 7 DOVALINA; JULIE DOVE; EYDIE DOYLE; THOMAS DURELL; AMBER 8 DURHAM; KENDALL DUSENBERRY; CHEYENNE 9 EBERLE; GENA ELFELT; DERRICK ELLIOTT; JILLIAN ELLIOTT; STACI 10 ELLIS; STEVE ENCINIAS; SHANYCE ENGLISH; MADELYN ENOCHS; 11 CANDICE ERICKSON; CHRIS ERICKSON; KANDIS ERICKSON; 12 SABRINA ESPARZA; ERNESTO ESPINOZA; SORAYA M. ESPINOZA; 13 LAURA ESTRADA; NICO ESTRADA; ESTATE OF STACEE ETCHEBER; 14 VINCENT ETCHEBER; BRIANA EVANS; CYNTHIA EVANS; DENNIS 15 EVANS; WENDY EVERETT; KYLE EVINGER; ASHLEY FARGO; 16 MICHELLE FARIAS; ANGELA FAVIA; JEFFREY FEIG; RAFAEL 17 FELICIANO; LAUREN FERGUSON; JENNIE FERNANDES; MARYSSA 18 FIELDS; MELISSA FIERRO; BAYLEE FINCHER; BROOKE FINCHER; 19 MINDY FINCHER; AUSTIN FISHER; LYNDSAY FISHER; SUSAN 20 FITZGERALD; EMILY FLESHER; KRISTI FLESHER; ART FLORES; 21 DANIEL FLORES; STEVEN FLORES; JENNIFER FLUEGAL; MARLANA 22 FOLTZ; DONALD FORSYTH; ROCHELLE FORSYTH; KADEDRA 23 FOWLER; JUSTIN FRAME; BRITTANY FRIEND; CYNTHIA 24 FRISKE; AMANDA FROST; BOBBI FRYE; LORRAINE FUENTES; APRIL 25 GABANY; TINA GALARZA; ERICA GALLEGOS; MANDY GALLEGOS; 26 STEPHANIE GALLEGOS; ESTATE OF KERI GALVAN; JUSTIN GALVAN; 27 R.G., A MINOR; P.G., A MINOR; P.G., A MINOR; CELENA GARCIA; 28 CHRISTINA GARCIA; ERIC GARCIA; 39245596.3 COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 5 of 181 Page ID #:5 1 EUGENE GARCIA; RANDY GARCIA; STACY GARCIA; TERESA GARCIA; 2 LAURA GARDHOUSE; ELLENOR GARGANO; JOSE L. GARZA; PAIGE 3 GASPER; BRITTANY GEBHART; WILLIAM GEORGIA; GARRETT 4 GHAHYASI; MEILIN GIBBENS; ERIN GILL; JOHN GILMORE; KYLEE 5 GLASSCOCK; ROBERT GLAVIS; TERESA GLAVIS; TRISTI GLOVER; 6 MICHELL GOBLE; MICHELLE GOMES; ASHLEY GOMEZ; JULIE 7 GOMEZ; STEVEN GOMEZ; JEFFREY ALAN GONSALVES; ANDREA 8 GONZALES; DANIEL JOSEPH GONZALES; ALESHA GONZALEZ; 9 JESUS VINCENT GONZALEZ; MICHAEL GONZALEZ; MICHAEL 10 GOODNIGHT; DOREEN GORMAN; DELORES GRAY; JEANETTE GRAY; 11 NICOLE GRAY; REGINA GREEN; DAVID J. GRIJALBA; JENNIFER 12 GRIMM; GABRIEL GUERRERO; MIGUEL GUERRERO; MIKERRA 13 GUERRERO; TRISHA GUERRERO; ESTATE OF ROCIO GUILLEN; S.J., A 14 MINOR; A.J., A MINOR; THOMAS GUNDERSON; TAMMY HISCOX 15 GURULE; TAMMY M. GURULE; KIMBERLY GUTIERREZ; CRYSTAL 16 HADLEY; DEBORAH HALL; STEVEN HALL; TRAVIS HALL; MICHELLE 17 HAMEL; KIERSTEN HARLING; SIMON HARLING; BRANDON 18 HARLOW; REGINA ANNE HARRIS; LISA HARTZ; MELINDA HAWKINS; 19 BREANNA HAYDEN; KILEY HAYDEN; KRISTINA HAYDEN; 20 LARRY HAYDEN; CORI HAYNES; BRYCE HEATHCOAT; JENNIFER 21 HEIDT; STEVEN HEIRSHBERG; WENDY HEIRSHBERG; BRANDON 22 HELMICK; JUSTIN HENDERSON; KRISTINE HENDERSON; ANDREA 23 HENNING; JUSTIN HEREDIA; HEATHER HERNANDEZ; REBECCA 24 HERNANDEZ; RICARDO HERNANDEZ; EMMITT HICKMAN; 25 ERIC HIGGINS; DIANE HILL; TYLER HILL; TERESA HIMLEY; JEFF 26 HINES; WHITNEY LINN HINNANT; LAUREN HITT; KENDRA HOBBS; 27 PATRICK HOBBS; LEIGH ANN HODGSON; KATHERINE HOEY; 28 BRYAN HOFFRICHTER; DONNA 39245596.3 COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 6 of 181 Page ID #:6 1 HOLDEN; TANNA HOLDERLE; ALBERT HOLGUIN; CINDY 2 HOLGUIN; LISA HOLGUIN; JOHN HOLLADAY; MELISSA HOLMQUIST; 3 VANESSA HOLUB; ALEXIS HOOD; TAYLOR HOOD; BRENDAN 4 HOOLIHAN; BRITTANY HOPKINS; MICHELLE HOWLETT; MALISA 5 HOYME; DEBRA HUDSON; LEANNE HUGGINS; LAURIE HULBERT; JULIE 6 HUNTSINGER; RYAN HUNTSINGER; TAYLOR HURWIT; BRET IVEY; 7 ALICIA JACKSON; THOMAS S. JACOBUS; CHRISTOPHER JAKSHA; 8 PHILIP JARDELL; JOANNA JASHIMOTO; AARON E. JENKINS; 9 JESSICA ANN JENKINS; TERESA JENSEN; MIRANDA JESSEN; SARAH 10 JICK; RENEE JIMENEZ; LANESHIA JOHNSON; MONTA JOHNSON; 11 MICHELLE JONES; MISTY JONES; ROB JONES; SHAHEED JONES; 12 CLARICE KAHIA; TED KALNAS; LORI KAMMER; TODD KAMMER; 13 MICHAEL KAPLISH; MIRTA KATNICH; SCOTT KEERAN; 14 VALERIE MELISSA KEERAN; ALAINA KELLY; DEBRA KELLY; 15 WILLIAM M. KELLY; KYLE KENNEDY; BRENDA KENT; KELSI 16 KESSLER; BRIAN KETTERING; YVETTE KETTERING; SANA 17 KHADER; JOANNA KILMA; JAMES KIRK; JUDIE JEAN KIRKSEY; 18 NICOLE KIRSHNER; MATTHEW KLEMMER; REBECCA KNEPPER; 19 KASH KNUDSON; JAZMAN GLOVER KOWALCZYK; MICHAEL 20 KRETSCHMAR; LAUREN CHRISTINE KRUEGER; MADISYN 21 KUNTZ; SCOTT T. KUNTZ; BRITTANY LAJOIE; MICHAEL 22 LANDRON; BROOKE LANEY; LOGAN LAPORTE; MITCHELL 23 LAPORTE; SUSIE LAPORTE; RICHARD LARSON; CHELSEA 24 LAURENT; JAMIE LAVERY; NICHOLAS LAWLOR; TIFFANI 25 LAWYER; SUSAN LEARN; CARA LEDERGERBER; RUTH LEGASPI; 26 DELANE LEIVAS; DELANIE LEONE; CATHERINE LESTER; HALEY 27 LEWIS; JUDITH LEYN; LINDA LIEWSUWANPHONG; PRIDEE J. 28 LIEWSUWANPHONG; SOPHIA 39245596.3 COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 7 of 181 Page ID #:7 1 LIMA; MICHAEL LJUBIC; MICHELLE LJUBIC; NIKOLAS 2 LJUBIC; ELVIA LLAMAS; MANUEL LLAMAS; DELANEY LLANUSA; 3 VALARIE LOERA; LEAH LOEWENTHAL; ARLA LONCAR; 4 BLAKE LONCAR; ALMA LOPEZ; KIMBERLY LORING; LETICIA 5 LUNA; A.M., A MINOR; BO MAGEE; KELCY MAIO; CLAUDIA MAJALCA; 6 EMILY MAJER; BRIAN MALLETTE; JEFF MANAHAN; KEVIN 7 MANAHAN; ASHLEY MANSPERGER; THOMAS MARTIN; 8 ANDREW MARTINEZ; ELISA MARTINEZ; REGINA R. MARTINEZ; 9 SALVADOR MARTINEZ; SOMER MARTINEZ; TONY MARTINEZ; 10 WILLIAM MASON; ADAM MATZ; HOLLY MAYES; CHARLES 11 MAYFIELD; CHRISTINE A. MAYFIELD; CHARLES MAYFIELD 12 IV; GENEVIEVE MAZZA; SHANDE MCCANN; KAREN MCCORKLE; 13 DANIEL MCDONALD; LONTISHA MCGILBERRY; JULIE MCGINIS; 14 CHERISH MCGUIRE; STEPHANIE MCKIERNAN; CHERYL 15 MCPHERSON; MARK MCSHANE; ASHLEY-DAWN L. MEAD; DAVID 16 MEDINA; JOHNATHAN DANIEL MEDINA; RACHELLE MELOCOTON; 17 RAYMOND MERKLEY; JIM MERRIFIELD; ESTATE OF PATRICIA 18 MESTAS; DEREK MILLER; KAYLA MILLS; MELISSA MINA; KEITH 19 MINEO; ROSA MIRANDA; ALEXANDRIA MITCHELL; DEBRA 20 MITCHELL; ROBIN MONTER ; MICHELLE MONTOYA; DODI 21 MOORE; LISA MORAN; BAMBI RENE MOREAU; SCOTT MOREAU; 22 BRITNIE L. MORGAN; CANDICE MORGAN; ROGER MOZDA; JILLIAN 23 MUELLER; JONATHAN MULLIGAN; LISA MUNOZ; KEVIN MURPHY; 24 CHRIS W. MURRAY; SHARMEN MURRAY; LISA MUZYCKA; JOSEPH 25 M. NAPOLI; MARISSA NARVAEZ; BRITTANY NEGRETTE; JOANNE 26 NELSON; ROBERT TROY NELSON; MARISA NEWMAN; FRANK 27 NICASSIO; GREGORY NIX; CHERIE NOLL; JEANETTE NUGENT; ANA 28 NUNEZ; LUIS NUNEZ; ELIZABETH 39245596.3 COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 8 of 181 Page ID #:8 1 OKORO; LINDSAY OKRAY; BRIAN O'LEARY; CARRIE O'LEARY; 2 VIRGINIA OLEN; RENEE OLIVER; LEONA OLSON; CYNTHIA OLVERA; 3 ARIEL ONTMAN; CLAUDIA OROPEZA; MICHELLE OROZCO; 4 THERESA ORTIZ; TAWANYA OTTO; DESTINY PACHECO; ELIJAH 5 PACHECO; LESLIE LYNN PAIZ; ROCKY PALERMO; MELANIE 6 PALMER; SALLY PALMER; HALEY PANNO; KYLIE PANNO; COLLIN 7 PARKER; ESTATE OF RACHAEL PARKER; REIGHLYNN PARSLEY; 8 JASON PARSONS; DAVON PATTERSON; MICHAEL 9 PATTERSON II; JANICE PENNINGTON; KIMBERLEE 10 PEOPLES; ELIZABETH PEREZ; PAUL PEREZ; ERIC PERKINS; DENINE 11 PETERS; DANYALE PETTERSON; NATHAN PHIPPEN; TRAVIS 12 PHIPPEN; ESTATE OF JOHN PHIPPEN; A.P., A MINOR; BRIAN 13 PICKENS; BERSABE PINEDA; JACK PINKSTON; LEONEL M. PLATA; 14 KARLEE POE; MYLIKA POPE; BRENT POPPEN; KEITH POWERS; 15 JESSICA PRESTEN; SHAWN PRICE; DENISE PROVENCIO; KENDALL 16 QUIROZ; MAGEE R.SEGAL; DOMINIC RABANAL; DIEGO 17 ARMANDO RAMIREZ; FRANCES RAMIREZ; KRYSTAL RAMIREZ; 18 RENEE RAMIREZ; SARA RAMIREZ; ERICA RAMOS; CARISSA RASH; 19 CODY RASH; DAVID RASMUSSON; MICHELLE RASMUSSON; JACOB 20 RATLIFF; JACOB RATLIFF; GLENDA REBOLLAR; MATTHEW C. REED; 21 TRICIA SEAN REED; LYNNE REICK; BRODY RENAUD; AMBER RENCH; 22 JASARA REQUEJO; FRANCISCO RESENDIZ; BRENDA RESNICK; 23 KRISTINA REYES; RALPH REYES; TARA REYES; MARION REYNOLDS; 24 WILLIAM REYNOLDS; STEVEN RIBOVICH; MARIE RICE; GINA 25 RICHARD; MINDY RITTER; HEATHER RIVERA; RAYMOND A. 26 RIVERA; JADE RIXEY; KURT ROBERTS; MICHAEL ROBERTSON; 27 TIMOTHY ROBINSON; BERNADETTE ROCHA; JENNIFER 28 ROCKWELL; SAUL RODRIGUEZ; 39245596.3 COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 9 of 181 Page ID #:9 1 MICHAEL ROGOZIK; MONICA ROGOZIK; MARCELINA ROJAS; 2 CLAUDIA ROMERO; HARRY ROMERO; SUSAN ROSE; ANNA 3 ROSS; DIXIE ROYBAL; ESTATE OF CHRISTOPHER ROYBAL; CHANTEL 4 RUBIO; LISA RUDBERG; LUCIA RUDELA; LAURA RUIZ; AMANDA 5 RUMBLE; JOANNE RUSCONI; MICHAEL COTY RYE; ERIC RYMER; 6 RONI RYMER; H.S., A MINOR; ALLISON SAELEE; JUSTINE SALAS; 7 VICTORIA SALAS; CRYSTAL SALAZAR; RENEE SALAZAR; SELSO 8 SALAZAR; AMANDA SALMON; AMANDA SAMBRANO; JANAE 9 SAMBRANO; JEFFERY SAMBRANO; STEPHEN SAMBRANO; ETHAN 10 SANCHEZ; GEORGE SANCHEZ; MARIE SANCHEZ; SAVANNAH 11 SANCHEZ; TREVOR SANDERS; ERNESTINE SANDOVAL; CALIA 12 SANFORD; INA SARKISSIAN; NELA SARKISSIAN; CASEY SCANDLYN; 13 ILENE SCANDLYN; DAVID SCANTLIN; MICHELLE SCANTLIN; 14 RYAN L. SCANTLIN; DAVID SCHARMACK; IRENE SCHARMACK; 15 REBEKAH SCHEUSSLER; ALICE SCHMIDT; JEREMY SCHMIDT ; LISA 16 SCHNEIDER; MARK SCHNEIDER; MICHELLE SCHONEMAN; ROBERT 17 SCHRODE; JONATHAN SCHUSSLER; MICHAEL SCOTT; JANET SEEGER; 18 ALICIA SEGOVIA; GILBERT SEGOVIA; CHERYL SEGUIN; FRED 19 SEGUIN; TOMMIE SERRANO; DAVID SHERIFF; REMO SHETH; 20 MICHAEL K. SHOLAN; ANTHONY SILVA; ELAINE SILVESTRE; 21 CHEYENNE NICOLE SIMON; HALEY SISNEROS; BUDDY SKIDMORE; LEE 22 SKOLNICK; SHELBY SLIFKA; JONATHAN SLONIGER; STEPHANIE 23 SMARKER; KAREN ELAINE SMERBER; AMBER SMITH; DANA L. 24 SMITH; RYAN SMITH; RYAN ONEIL SMITH; DANIELLE SMUDDE; MISTY 25 SNITZER; STEPHANIE SOTOMAYOR; KATEY SOUZA; 26 CHERYL SPENCER; KEOSCHA E. SPENCER; KORTNEY SPENCER; 27 MICHELLE E. SPENCER; SAVANNAH SPENCER; STEPHANIE 28 SPENCER; SUZANNE SPENCER; 39245596.3 COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 10 of 181 Page ID #:10 1 DAVID SPRING; SHANNON SPRINGER; TROY SPRINGER; 2 ROBERT STAGGS; DANIEL STAPLES; SAMUEL STAPLES; 3 KRISTINA STAPLES; DAVID STATTER; VERONICA STATTER; 4 JEFFREY STEFFENS; KATIE STERN; PARKER STEVENS; STEVE 5 STEWART; TAMARA J. STEWART; MICHAELA STILWELL; DANA 6 STOUT-WILSON; LINDSAY STRAGIER; JOSHUA K. STRATTON; 7 AMBER STREID; SHANDI STRONG; MICHELLE STUEBE; SUSANNA 8 SUARD; CLINT SUNDEEN; KELLIE SUNDEEN; KYLE C. SUNDEEN; 9 BRANDI SWAN; NICHOLAS SWARTZ; YVETTE SWARTZ; 10 LYNNSEY SWEET; B.T., A MINOR; ERIN TABER; RUBEN 11 TALAMANTEZ; MARIE TAUTRIM; MICHAEL TAUTRIM; BRIANNA 12 TAYLOR; JASON TAYLOR; JOHN TAYLOR; TIFFANY TAYLOR; 13 DESIREE TEMPLE; ROCKY TEPESANO; JANELLE TERKEURST; 14 DEBORAH THOMAS; JEFFREY THOMAS; EVAN TILLEMA; 15 LINDSAY TILLEMA; JENNIFER TILLMAN; JOSHUA TINOCO; 16 LANNA TINOCO; SARAH TISCARENO; ALFREDO TOLEDO; 17 KENNETH TONKOVICH; JOHNNY TOSCANO; RHONDA TRASK; 18 ROBERT TREMATERRA; HAMIDA TRUJILLO; JACQUELYN TRUJILLO; 19 LIGIA URIARTE; ALEJANDRA URIBE; RICARDO URIBE; LISA 20 VALDES; ERIN VALENZUELA; JENNIFER VAN VLYMEN; 21 NATHALIE VANDERSTAY; GERARD VANGERWEN; AMY VIGER; 22 JEREMY VIGER; DILLON VILLALOBOS; DON VILLALOBOS; 23 LISA VILLALOBOS; PARISSE VILLALOBOS; PETER VIOLAS; 24 CECELIA JOYA WALACH; REBECCA WALTMAN; DONALD WASHBROOK 25 JR.; AMANDA WECHSLER; CARRIE WEIDENKELLER; TRICIA WELCH; 26 KEVIN WELLS; SERENA WEST; CHRISTOPHER WETZEL; GINA B. 27 WHEELER; DEREK WHITE; GREG WHITE; VICTORIA WHITE; 28 PRESLEY WICK; TRACIE P. WIGHT; 39245596.3 COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 11 of 181 Page ID #:11 1 STACY WILBANKS; REBECCA WILKEN; ANNA WILLIAMS; JOSEPH 2 N. WILLIAMS; STANLEY WILLIAMS; JAMES WILLIAMSON; 3 MARCUS WILSON; MCKAYLA WILSON; KATELYN WING; KERRY 4 WISDEN; ANTHONY WOOD; SHAWNA WOOD; JAEGER 5 WOODSON; JADE WRIGHT; JEFF WRIGHT; TOME XAYAVONG; 6 BRETT YEAKEL; SHAWNA YORK; BRANDON YOUNG; LAURA 7 ZARATE; SHANNON ZEEMAN; AND SHARLA ZOTEA, 8 Defendants. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 39245596.3 COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 12 of 181 Page ID #:12 INTRODUCTION 1 2 1. On October 1, 2017, Stephen Paddock carried out a mass attack at the 3 Route 91 Harvest Festival in Las Vegas, Nevada. 4 2. Paddock intended to inflict mass injury, death and destruction. He 5 killed 58 persons and injured some 500 others. Paddock’s attack resulted in the 6 highest number of deaths of any mass shooting in the Nation’s history. 7 3. Security for the concert was provided by Contemporary Services 8 Corporation, whose security services have been certified by the Secretary of 9 Homeland Security for protecting against and responding to acts of mass injury and 10 destruction. 11 4. Recognizing the national interest in such events, and in the 12 development and deployment of services certified by the Secretary of Homeland 13 Security to prevent and respond to such events, Congress has provided original and 14 exclusive federal jurisdiction for any claims of injuries arising out of or relating to 15 mass violence where services certified by the Department of Homeland Security 16 were deployed. 17 5. Plaintiff MGM Resorts Festival Grounds, LLC owns and operates the 18 Las Vegas Village, at 3901 South Las Vegas Boulevard, Las Vegas, Nevada 89119, 19 where the Route 91 Harvest Festival was held. Plaintiff Mandalay Bay, LLC owns 20 and operates the Mandalay Bay resort, which is adjacent to Las Vegas Village. 21 Plaintiff MGM Resorts International is the parent corporation, with 100% interest in 22 Plaintiff Mandalay Resort Group and an indirect 100% interest in Mandalay Bay, 23 LLC, and MGM Resorts Festival Grounds. Plaintiff MGM Resorts Venue 24 Management, LLC is a Nevada limited liability company. 25 6. Paddock carried out his mass attack on the concert from a room on the 26 32nd floor of the Mandalay Bay resort. 27 7. Following Paddock’s attack, over 2,500 individuals (“Claimants”) have 28 brought lawsuits, or threatened to bring lawsuits, against Plaintiffs MGM Resorts 39245596.3 -1- COMPLAINT FOR DECLARATORY RELIEF RE APPLICATION OF SAFETY ACT, 6 U.S.C. §§ 441-444 Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 13 of 181 Page ID #:13 1 Festival Grounds, LLC, MGM Resorts International, Mandalay Bay, LLC, 2 Mandalay Resort Group, and MGM Resorts Venue Management, LLC (collectively, 3 “the MGM Parties”), alleging that the MGM Parties (among others) are liable for 4 deaths, injuries, and emotional distress resulting from Paddock’s attack. Claimants 5 subsequently voluntarily dismissed these cases before they could be resolved, 6 apparently with the intent of refiling. 7 8. Named as defendants in this case are Claimants who have brought 8 lawsuits (which they subsequently voluntarily dismissed) against the MGM Parties, 9 alleging claims arising from Paddock’s attack, and persons who, through counsel, 10 have threatened to bring such claims against the MGM Parties. 11 9. Congress has enacted legislation to support the development of new 12 technologies and services to prevent and respond to mass violence. That legislation, 13 the Support Anti-Terrorism by Fostering Effective Technologies Act of 2002, 6 14 U.S.C. §§ 441-444 (also known by the acronym, the “SAFETY Act”), provides a 15 calibrated balance of remedies and limitations on liabilities arising from mass 16 attacks committed on U.S. soil where services certified by the Department of 17 Homeland Security were deployed. 18 10. In the case of Paddock’s mass attack, certified technologies or services 19 were deployed by a professional security company, Contemporary Services 20 Corporation (“CSC”), which was employed as the Security Vendor for the Route 91 21 concert. As alleged in more detail below, Paddock’s mass attack meets the 22 requirements of the SAFETY Act as set forth in the statute and the Regulations 23 promulgated by the Department of Homeland Security. 24 11. Defendants’ actual and threatened lawsuits implicate the services 25 provided by CSC because they implicate security at the concert, for example 26 security training, emergency response, evacuation, and adequacy of egress. 27 12. As a result, the SAFETY Act applies to and governs all actions and any 28 claims arising out of or relating to Paddock’s mass attack. There are five key 39245596.3 -2- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 14 of 181 Page ID #:14 1 aspects of the Act and implementing regulations promulgated by the Department of 2 Homeland Security as authorized and contemplated by the SAFETY Act. 6 C.F.R. 3 § 25.1 et seq. 4 13. First, the SAFETY Act creates a “Federal cause of action for claims 5 arising out of [or] relating to” an act of mass violence where certified services were 6 deployed and where such claims may result in losses to the Seller of the services. 6 7 U.S.C. § 442(a)(1). 8 14. Second, the SAFETY Act expressly provides the federal courts with 9 “original and exclusive jurisdiction over all actions for any claim for loss” arising 10 out of or related to such an attack. 6 U.S.C. § 442(a)(2). 11 15. Third, as confirmed by the Secretary’s implementing regulations 12 promulgated after enactment of the SAFETY Act, the federal cause of action created 13 by the statute is the exclusive claim available in such circumstances. 6 U.S.C. 14 § 442(a)(1). The regulations state: “There shall exist only one cause of action for 15 loss of property, personal injury, or death for performance or non-performance of 16 the Seller’s Qualified Anti–Terrorism Technology in relation to an Act of 17 Terrorism.” 6 C.F.R. § 25.7(d). 18 16. Fourth, the regulations further provide that “Such cause of action may 19 be brought only against the Seller of the Qualified Anti–Terrorism Technology and 20 may not be brought against the buyers, the buyers’ contractors, or downstream users 21 of the Technology, the Seller's suppliers or contractors, or any other person or 22 entity.” 6 C.F.R. § 25.7(d). 23 17. Fifth, to ensure compensation for victims in appropriate cases, the 24 SAFETY Act requires that the Seller “obtain liability insurance of such types and in 25 such amounts as shall be required in accordance with this section and certified by 26 the Secretary to satisfy otherwise compensable third-party claims arising out of, 27 relating to, or resulting from an act of terrorism.” 6 U.S.C. § 443(a)(1). 28 39245596.3 -3- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 15 of 181 Page ID #:15 1 18. Congress enacted the SAFETY Act in recognition of the strong 2 national interest in encouraging the development and use of technologies and 3 services that can help prevent and respond to mass violence. The Act does so in part 4 by assurance of limited liability in the unfortunate event that an incident of mass 5 violence occurs and injuries occur despite the deployment of such technology. The 6 Act also does so by creating original and exclusive jurisdiction for the resolution of 7 all controversies in federal court. 6 U.S.C. § 442(a)(2). 8 19. The SAFETY Act expressly provides the federal courts with original 9 and exclusive jurisdiction over “all actions for and any claims for loss [or] injury” 10 arising out of or relating to a mass attack where certified services were provided and 11 where such claims may result in losses to the seller of those services. The Act and 12 the associated regulations make clear that any such claim against the MGM Parties 13 must be dismissed. 14 20. By this action, the MGM Parties seek a declaratory judgment and 15 further relief pursuant to the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 16 2202, that the MGM parties cannot be held liable to Defendants for deaths, injuries, 17 or other damages arising from Paddock’s attack. PARTIES 18 19 A. PLAINTIFFS 20 21. Plaintiff MGM RESORTS INTERNATIONAL is a Delaware 21 corporation with its principal place of business in Las Vegas, Nevada. Plaintiff 22 MGM RESORTS INTERNATIONAL is a citizen of Delaware and Nevada for 23 purposes of diversity jurisdiction. 24 22. Plaintiff MANDALAY RESORT GROUP is a Nevada corporation 25 with its principal place of business in Las Vegas, Nevada. MANDALAY RESORT 26 GROUP is a citizen of Nevada for purposes of diversity jurisdiction. 27 23. Plaintiff, MANDALAY BAY, LLC f/k/a MANDALAY CORP. is a 28 Nevada limited liability company with a single member, Mandalay Resort 39245596.3 -4- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 16 of 181 Page ID #:16 1 Group. Plaintiff MANDALAY BAY, LLC f/k/a MANDALAY CORP is a citizen 2 of Nevada for purposes of diversity jurisdiction. 3 24. Plaintiff MGM RESORTS FESTIVAL GROUNDS, LLC is a Nevada 4 limited liability company with a single member, Mandalay Resort Group. Plaintiff 5 MGM RESORTS FESTIVAL GROUNDS, LLC is a citizen of Nevada for purposes 6 of diversity jurisdiction. 7 25. Plaintiff MGM RESORTS VENUE MANAGEMENT, LLC is a 8 Nevada limited liability company with a single member, MGM Resorts 9 International. Plaintiff MGM RESORTS VENUE MANAGEMENT, LLC is a 10 citizen of Nevada and Delaware for purposes of diversity jurisdiction. 11 B. DEFENDANTS 12 26. Plaintiffs are informed and believe, and thereon allege, that defendant 13 David Aase is a resident of the State of California. Defendant has previously filed a 14 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 15 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 16 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 17 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 18 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 19 of the County of Los Angeles, State of California. 20 27. Plaintiffs are informed and believe, and thereon allege, that defendant 21 Gary Aase is a resident of the State of California. Defendant has previously filed a 22 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 23 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 24 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 25 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 26 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 27 of the County of Los Angeles, State of California. 28 39245596.3 -5- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 17 of 181 Page ID #:17 1 28. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Mark Abraham is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 6 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 7 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 8 of the County of Los Angeles, State of California. 9 29. Plaintiffs are informed and believe and thereon allege that Defendant 10 Andrea Abrams is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 30. Plaintiffs are informed and believe and thereon allege that Defendant 14 Daniel Abrams is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 31. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Luke Adam is a resident of the State of California. Defendant has previously filed a 19 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 20 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 21 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 22 Angeles Superior Court (“LASC”), case number BC687120. 23 32. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Robert Aguilar is a resident of the State of California. Defendant has previously 25 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 26 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 27 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Aguilar v. MGM, 28 39245596.3 -6- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 18 of 181 Page ID #:18 1 Plaintiffs are informed and believe that Defendant is a resident of the County of Los 2 Angeles, State of California. 3 33. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Gloria Aguirre is a resident of the State of California. Defendant has previously filed 5 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 6 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 7 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 8 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Los Angeles, State of California. 11 34. Plaintiffs are informed and believe, and thereon allege that on October 12 1, 2017, decedent Hannah Ahlers, was a resident of the State of California. 13 Plaintiffs are informed and believe and thereon allege that Defendants, the Estate of 14 Hannah Ahlers and Brian Ahlers (surviving husband, heir and successor-in-interest) 15 have, through counsel, made claims against Plaintiffs based upon the October 1, 16 2017, shooting incident in Las Vegas, Nevada, or, alternatively, has indicated an 17 intent to make such claims in the future (such as by way of the filing of a separate 18 lawsuit – now dismissed, by way of a letter of representation of counsel, or by way 19 of an evidence preservation letter from counsel). 20 35. Plaintiffs are informed and believe and thereon allege that Defendant 21 Marco Albertini is a resident of the State of California. Defendant has, through 22 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 23 October 1, 2017, shooting incident in Las Vegas, Nevada. 24 36. Plaintiffs are informed and believe, and thereon allege, that defendant 25 Renee Alcala is a resident of the State of California. Defendant has previously filed 26 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 27 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 28 Las Vegas, Nevada. Based on the allegations in that lawsuit, Huggins, et al. v. 39245596.3 -7- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 19 of 181 Page ID #:19 1 MGM, filed February 14, 2018, in the Los Angeles Superior Court (“LASC”), case 2 number BC694788, Plaintiffs are informed and believe that Defendant is a resident 3 of the County of Los Angeles, State of California. 4 37. Plaintiffs are informed and believe, and thereon allege, that defendant 5 Ernesto Alfaro is a resident of the State of California. Defendant has previously filed 6 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 7 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 8 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 9 Los Angeles Superior Court (“LASC”), case number BC684047. 10 38. Plaintiffs are informed and believe, and thereon allege, that defendant 11 Tenesha Alfaro is a resident of the State of California. Defendant has previously 12 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 13 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 14 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 15 Los Angeles Superior Court (“LASC”), case number BC684047. 16 39. Plaintiffs are informed and believe and thereon allege that Defendant 17 Sara Allegro is a resident of the State of California. Defendant has, through counsel, 18 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 19 2017, shooting incident in Las Vegas, Nevada. 20 40. Plaintiffs are informed and believe, and thereon allege, that defendant 21 Etta Allen is a resident of the State of California. Defendant has previously filed a 22 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 23 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 24 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 25 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 26 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 27 of the County of Los Angeles, State of California. 28 39245596.3 -8- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 20 of 181 Page ID #:20 1 41. Plaintiffs are informed and believe and thereon allege that Defendant 2 Leanne Altamirano is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 42. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Ruben Alulema is a resident of the State of California. Defendant has previously 7 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 8 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 9 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 10 Los Angeles Superior Court (“LASC”), case number BC684047. 11 43. Plaintiffs are informed and believe and thereon allege that Defendant 12 Alex Alvarez is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 44. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Daniel Earl Alvarez is a resident of the State of California. Defendant has previously 17 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 18 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 19 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 20 Los Angeles Superior Court (“LASC”), case number BC684047. 21 45. Plaintiffs are informed and believe and thereon allege that Defendant 22 Joanna Alvarez is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 46. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Lindsey Alvarez is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -9- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 21 of 181 Page ID #:21 1 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 47. Plaintiffs are informed and believe and thereon allege that Defendant 4 Danielle Ambrose is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 48. Plaintiffs are informed and believe and thereon allege that Defendant 8 Aletha Anderson is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 49. Plaintiffs are informed and believe and thereon allege that Defendant 12 Natalie Anderson is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 50. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Rebecca Ann Anderson is a resident of the State of California. Defendant has 17 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 18 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 19 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 20 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 21 BC684047. 22 51. Plaintiffs are informed and believe and thereon allege that Defendant 23 Ryan Anderson is a resident of the State of California. Defendant has, through 24 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 25 October 1, 2017, shooting incident in Las Vegas, Nevada. 26 52. Plaintiffs are informed and believe and thereon allege that Defendant 27 Shannon Anderson is a resident of the State of California. Defendant has, through 28 39245596.3 -10- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 22 of 181 Page ID #:22 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 53. Plaintiffs are informed and believe and thereon allege that Defendant 4 Jennifer Aparicio is a resident of the State of California, County of Los Angeles. 5 Defendant has, through counsel, asserted or threatened to assert claims against 6 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 7 54. Plaintiffs are informed and believe and thereon allege that Defendant 8 Brenden Araujo is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 55. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Cassie Ardito is a resident of the State of California. Defendant has previously filed 13 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 56. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Richard Ardito is a resident of the State of California. Defendant has previously 19 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 20 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 21 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 22 Los Angeles Superior Court (“LASC”), case number BC684047. 23 57. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Jesus Astua is a resident of the State of California. Defendant has previously filed a 25 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 26 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 27 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 28 Los Angeles Superior Court (“LASC”), case number BC684047. 39245596.3 -11- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 23 of 181 Page ID #:23 1 58. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Lisa Awalt is a resident of the State of California. Defendant has previously filed a 3 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 59. Plaintiffs are informed and believe, and thereon allege, that defendant 8 D.B., a minor, is a resident of the State of California. Defendant has previously filed 9 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 10 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 11 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 12 Los Angeles Superior Court (“LASC”), case number BC684047. 13 60. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Codi Babcock is a resident of the State of California. Defendant has previously filed 15 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 16 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 17 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 18 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 19 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 20 of the County of Los Angeles, State of California. 21 61. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Cheyene Bacon-Meriweather is a resident of the State of California. Defendant has 23 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 24 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 25 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 26 Mayfield, et al. v. MGM, filed December 15, 2017, in the Los Angeles Superior 27 Court (“LASC”), case number BC687120, Plaintiffs are informed and believe that 28 Defendant is a resident of the County of Los Angeles, State of California. 39245596.3 -12- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 24 of 181 Page ID #:24 1 62. Plaintiffs are informed and believe and thereon allege that Defendant 2 Christopher Badorek is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 63. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Tracey Baker is a resident of the State of California. Defendant has previously filed 7 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 8 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 9 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 10 Los Angeles Superior Court (“LASC”), case number BC684047. 11 64. Plaintiffs are informed and believe and thereon allege that Defendant 12 Shannon Balas is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 65. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Tiffany Ball is a resident of the State of California. Defendant has previously filed a 17 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 18 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 19 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 20 Los Angeles Superior Court (“LASC”), case number BC684047. 21 66. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Mary Banta is a resident of the State of California. Defendant has previously filed a 23 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 24 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 25 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 26 Los Angeles Superior Court (“LASC”), case number BC684047. 27 67. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Ted Banta is a resident of the State of California. Defendant has previously filed a 39245596.3 -13- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 25 of 181 Page ID #:25 1 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 2 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 3 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 68. Plaintiffs are informed and believe and thereon allege that Defendant 6 Jason Banville is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 69. Plaintiffs are informed and believe and thereon allege that Defendant 10 Tegan Banville is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 70. Plaintiffs are informed and believe and thereon allege that Defendant 14 Jasmine Barbusca is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 71. Plaintiffs are informed and believe, and thereon allege that on October 18 1, 2017, decedent Carrie Barnette, was a resident of the State of California. 19 Plaintiffs are informed and believe and thereon allege that Defendant, the Estate of 20 Carrie Barnette, has, through counsel, made claims against Plaintiffs based upon the 21 October 1, 2017, shooting incident in Las Vegas, Nevada, or, alternatively, has 22 indicated an intent to make such claims in the future (such as by way of the filing of 23 a separate lawsuit – now dismissed, by way of a letter of representation of counsel, 24 or by way of an evidence preservation letter from counsel). 25 72. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Tinella Barranco is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -14- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 26 of 181 Page ID #:26 1 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 2 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 3 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 4 of the County of Los Angeles, State of California. 5 73. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Ronald A. Barreras Jr. is a resident of the State of California. Defendant has 7 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 8 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 9 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 10 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 11 BC684047. 12 74. Plaintiffs are informed and believe, and thereon allege, that defendant 13 Donovan (Donny) Barthel is a resident of the State of California. Defendant has 14 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 15 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 16 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 17 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 18 BC684047. 19 75. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Monique D. Barthel is a resident of the State of California. Defendant has 21 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 22 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 23 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 24 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 25 BC684047. 26 76. Plaintiffs are informed and believe and thereon allege that Defendant 27 Courtney Bean is a resident of the State of California. Defendant has, through 28 39245596.3 -15- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 27 of 181 Page ID #:27 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 77. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Brad Beauchamp is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 8 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Los Angeles, State of California. 11 78. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Dawn Beauchamp is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 16 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 17 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 18 of the County of Los Angeles, State of California. 19 79. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Aleisa Bebee is a resident of the State of California. Defendant has previously filed 21 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 24 Los Angeles Superior Court (“LASC”), case number BC684047. 25 80. Plaintiffs are informed and believe and thereon allege that Defendant 26 Ashley Becker is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -16- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 28 of 181 Page ID #:28 1 81. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Sean Beeson is a resident of the State of California. Defendant has previously filed a 3 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 82. Plaintiffs are informed and believe and thereon allege that Defendant 8 Jonathon Bell is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 83. Plaintiffs are informed and believe and thereon allege that Defendant 12 Annalise Belmares is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 84. Plaintiffs are informed and believe and thereon allege that Defendant 16 Meghan Belmares is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 85. Plaintiffs are informed and believe and thereon allege that Defendant 20 Jonathan Beltran is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 86. Plaintiffs are informed and believe and thereon allege that Defendant 24 Daniel R. Best is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 87. Plaintiffs are informed and believe and thereon allege that Defendant 28 Carly Betzler is a resident of the State of California. Defendant has, through 39245596.3 -17- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 29 of 181 Page ID #:29 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 88. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Taylor Blaiser is a resident of the State of California. Defendant has previously filed 5 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 6 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 7 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 8 Los Angeles Superior Court (“LASC”), case number BC684047. 9 89. Plaintiffs are informed and believe and thereon allege that Defendant 10 Jannette Blake is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 90. Plaintiffs are informed and believe and thereon allege that Defendant 14 Paula Blakeley is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 91. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Jodi Boatwood is a resident of the State of California. Defendant has previously 19 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 20 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 21 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 22 Los Angeles Superior Court (“LASC”), case number BC684047. 23 92. Plaintiffs are informed and believe and thereon allege that Defendant 24 Amanda Bobb is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 93. Plaintiffs are informed and believe and thereon allege that Defendant 28 Dylan Boden is a resident of the State of California. Defendant has, through counsel, 39245596.3 -18- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 30 of 181 Page ID #:30 1 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 2 2017, shooting incident in Las Vegas, Nevada. 3 94. Plaintiffs are informed and believe and thereon allege that Defendant 4 Emily Boden is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 95. Plaintiffs are informed and believe and thereon allege that Defendant 8 Joy Boden is a resident of the State of California. Defendant has, through counsel, 9 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 10 2017, shooting incident in Las Vegas, Nevada. 11 96. Plaintiffs are informed and believe and thereon allege that Defendant 12 Maddison Boden is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 97. Plaintiffs are informed and believe and thereon allege that Defendant 16 Mark Boden is a resident of the State of California. Defendant has, through counsel, 17 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 18 2017, shooting incident in Las Vegas, Nevada. 19 98. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Crystal Bolke is a resident of the State of California. Defendant has previously filed 21 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 24 Los Angeles Superior Court (“LASC”), case number BC684047. 25 99. Plaintiffs are informed and believe and thereon allege that Defendant 26 Dianella Bono is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -19- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 31 of 181 Page ID #:31 1 100. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Maureen Bonte is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 6 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 7 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 8 of the County of Los Angeles, State of California. 9 101. Plaintiffs are informed and believe and thereon allege that Defendant 10 Nicole Bontempo is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 102. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Paul Boone is a resident of the State of California. Defendant has previously filed a 15 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 16 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 17 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 18 Los Angeles Superior Court (“LASC”), case number BC684047. 19 103. Plaintiffs are informed and believe, and thereon allege that on October 20 1, 2017, decedent Candice Bowers, was a resident of the State of California. 21 Plaintiffs are informed and believe and thereon allege that the Defendants, the Estate 22 of Candice Bowers, Kurtis Anthony Bowers (surviving son, heir, and successor-in23 interest), K.L.A. (a minor, heir, and successor-in-interest), and A.R.B. (a minor, 24 heir, and successor-in-interest), are residents of the County of Los Angeles, State of 25 California, who have, through counsel, made claims against Plaintiffs based upon 26 the October 1, 2017, shooting incident in Las Vegas, Nevada, by way of the filing of 27 a separate lawsuit – now dismissed). The residency of these Defendants was 28 represented to a court in a Complaint in the dismissed action Bowers, et al. v. MGM, 39245596.3 -20- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 32 of 181 Page ID #:32 1 filed May 10, 2018, in the Los Angeles Superior Court (“LASC”), case number 2 BC705803. 3 104. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Vedamay Bradford is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Vanderstay, et al. v. 8 MGM, filed November 13, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC683403, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Los Angeles, State of California. 11 105. Plaintiffs are informed and believe and thereon allege that Defendant 12 Michael Bradley is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 106. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Cindy Bradshaw is a resident of the State of California. Defendant has previously 17 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 18 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 19 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 20 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 21 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 22 of the County of Ventura, State of California. 23 107. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Robert (Bobby) Bradshaw is a resident of the State of California. Defendant has 25 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 26 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 27 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 28 Mayfield, et al. v. MGM, filed December 15, 2017, in the Los Angeles Superior 39245596.3 -21- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 33 of 181 Page ID #:33 1 Court (“LASC”), case number BC687120, Plaintiffs are informed and believe that 2 Defendant is a resident of the County of Ventura, State of California. 3 108. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Lauren Brady is a resident of the State of California. Defendant has previously filed 5 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 6 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 7 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 8 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Los Angeles, State of California. 11 109. Plaintiffs are informed and believe, and thereon allege, that defendant 12 David Brake is a resident of the State of California. Defendant has previously filed a 13 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 110. Plaintiffs are informed and believe and thereon allege that Defendant 18 Stevee Brancato is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 111. Plaintiffs are informed and believe and thereon allege that Defendant 22 James Brightly is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 112. Plaintiffs are informed and believe and thereon allege that Defendant 26 Mailys Brightly is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -22- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 34 of 181 Page ID #:34 1 113. Plaintiffs are informed and believe and thereon allege that Defendant 2 Edward Brown is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 114. Plaintiffs are informed and believe and thereon allege that Defendant 6 Erika Brown is a resident of the State of California. Defendant has, through counsel, 7 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 8 2017, shooting incident in Las Vegas, Nevada. 9 115. Plaintiffs are informed and believe and thereon allege that Defendant 10 Ronda Brown is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 116. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Stephanie Brown is a resident of the State of California. Defendant has previously 15 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 16 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 17 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 18 Los Angeles Superior Court (“LASC”), case number BC684047. 19 117. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Stacey Brown-Fusano is a resident of the State of California. Defendant has 21 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 22 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 23 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 24 Mayfield, et al. v. MGM, filed December 15, 2017, in the Los Angeles Superior 25 Court (“LASC”), case number BC687120, Plaintiffs are informed and believe that 26 Defendant is a resident of the County of Los Angeles, State of California. 27 118. Plaintiffs are informed and believe and thereon allege that Defendant 28 Tayler Brunner is a resident of the State of California. Defendant has, through 39245596.3 -23- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 35 of 181 Page ID #:35 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 119. Plaintiffs are informed and believe and thereon allege that Defendant 4 John Bui is a resident of the State of California. Defendant has, through counsel, 5 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 6 2017, shooting incident in Las Vegas, Nevada. 7 120. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Treanesha LaShonda Bullion is a resident of the State of California. Defendant has 9 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 10 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 11 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 12 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 13 BC684047. 14 121. Plaintiffs are informed and believe and thereon allege that Defendant 15 Terry Burk is a resident of the State of California. Defendant has, through counsel, 16 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 17 2017, shooting incident in Las Vegas, Nevada. 18 122. Plaintiffs are informed and believe and thereon allege that Defendant 19 Andrea Bustamante is a resident of the State of California. Defendant has, through 20 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 21 October 1, 2017, shooting incident in Las Vegas, Nevada. 22 123. Plaintiffs are informed and believe and thereon allege that Defendant 23 Gabriella Bustamante is a resident of the State of California. Defendant has, through 24 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 25 October 1, 2017, shooting incident in Las Vegas, Nevada. 26 124. Plaintiffs are informed and believe, and thereon allege, that defendant 27 Hector Caballero is a resident of the State of California. Defendant has previously 28 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 39245596.3 -24- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 36 of 181 Page ID #:36 1 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 2 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 3 Los Angeles Superior Court (“LASC”), case number BC684047. 4 125. Plaintiffs are informed and believe, and thereon allege, that defendant 5 Heather L. Cain is a resident of the State of California. Defendant has previously 6 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 7 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 8 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 9 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 10 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 11 of the County of Los Angeles, State of California. 12 126. Plaintiffs are informed and believe and thereon allege that Defendant 13 Jennifer Campas is a resident of the State of California. Defendant has, through 14 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 15 October 1, 2017, shooting incident in Las Vegas, Nevada. 16 127. Plaintiffs are informed and believe and thereon allege that Defendant 17 Jennifer L. Campbell is a resident of the State of California. Defendant has, through 18 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 19 October 1, 2017, shooting incident in Las Vegas, Nevada. 20 128. Plaintiffs are informed and believe and thereon allege that Defendant 21 Lynzee Campbell is a resident of the State of California. Defendant has, through 22 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 23 October 1, 2017, shooting incident in Las Vegas, Nevada. 24 129. Plaintiffs are informed and believe, and thereon allege, that defendant 25 Julia Campos is a resident of the State of California. Defendant has previously filed 26 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 27 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 28 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 39245596.3 -25- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 37 of 181 Page ID #:37 1 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 2 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 3 of the County of Los Angeles, State of California. 4 130. Plaintiffs are informed and believe and thereon allege that Defendant 5 Karen Canada is a resident of the State of California. Defendant has, through 6 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 7 October 1, 2017, shooting incident in Las Vegas, Nevada. 8 131. Plaintiffs are informed and believe, and thereon allege, that defendant 9 Ingrid Canelo is a resident of the State of California. Defendant has previously filed 10 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 11 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 12 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 13 Los Angeles Superior Court (“LASC”), case number BC684047. 14 132. Plaintiffs are informed and believe and thereon allege that Defendant 15 Renee Canelo is a resident of the State of California. Defendant has, through 16 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 17 October 1, 2017, shooting incident in Las Vegas, Nevada. 18 133. Plaintiffs are informed and believe, and thereon allege, that defendant 19 Mary Canich is a resident of the State of California. Defendant has previously filed 20 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 21 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 22 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 23 Los Angeles Superior Court (“LASC”), case number BC684047. 24 134. Plaintiffs are informed and believe and thereon allege that Defendant 25 Emily Cantrell is a resident of the State of California. Defendant has, through 26 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 27 October 1, 2017, shooting incident in Las Vegas, Nevada. 28 39245596.3 -26- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 38 of 181 Page ID #:38 1 135. Plaintiffs are informed and believe and thereon allege that Defendant 2 Brittnie Nicole Cardenas is a resident of the State of California, County of Los 3 Angeles. Defendant has, through counsel, asserted or threatened to assert claims 4 against Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, 5 Nevada. 6 136. Plaintiffs are informed and believe, and thereon allege, that defendant 7 Jessica Carey is a resident of the State of California. Defendant has previously filed 8 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 9 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 10 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 11 Los Angeles Superior Court (“LASC”), case number BC684047. 12 137. Plaintiffs are informed and believe and thereon allege that Defendant 13 Kate Carlin is a resident of the State of California. Defendant has, through counsel, 14 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 15 2017, shooting incident in Las Vegas, Nevada. 16 138. Plaintiffs are informed and believe, and thereon allege, that defendant 17 Kari Carlstrom is a resident of the State of California. Defendant has previously 18 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 19 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 20 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 21 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 22 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 23 of the County of Los Angeles, State of California. 24 139. Plaintiffs are informed and believe and thereon allege that Defendant 25 Alexander Carriaga is a resident of the State of California. Defendant has, through 26 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 27 October 1, 2017, shooting incident in Las Vegas, Nevada. 28 39245596.3 -27- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 39 of 181 Page ID #:39 1 140. Plaintiffs are informed and believe and thereon allege that Defendant 2 Kimberly Carriaga is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 141. Plaintiffs are informed and believe and thereon allege that Defendant 6 Matthew Carrillo is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 142. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Ian Carter is a resident of the State of California. Defendant has previously filed a 11 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 12 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 13 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 14 Los Angeles Superior Court (“LASC”), case number BC684047. 15 143. Plaintiffs are informed and believe and thereon allege that Defendant 16 Elizabeth A. Carvalho is a resident of the State of California. Defendant has, 17 through counsel, asserted or threatened to assert claims against Plaintiffs based upon 18 the October 1, 2017, shooting incident in Las Vegas, Nevada. 19 144. Plaintiffs are informed and believe and thereon allege that Defendant 20 Connor Casarez is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 145. Plaintiffs are informed and believe and thereon allege that Defendant 24 Vanessa Case is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 146. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Michelle Ann Cashman is a resident of the State of California. Defendant has 39245596.3 -28- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 40 of 181 Page ID #:40 1 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 2 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 3 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 4 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 5 BC684047. 6 147. Plaintiffs are informed and believe and thereon allege that Defendant 7 Carley Cass is a resident of the State of California. Defendant has, through counsel, 8 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 9 2017, shooting incident in Las Vegas, Nevada. 10 148. Plaintiffs are informed and believe, and thereon allege that on October 11 1, 2017, decedent Andrea Castilla, was a resident of the State of California. 12 Plaintiffs are informed and believe and thereon allege that Defendants, the Estate of 13 Andrea Castilla, and Gus Castilla (surviving father, heir, and successor-in-interest to 14 decedent) have, through counsel, made claims against Plaintiffs based upon the 15 October 1, 2017, shooting incident in Las Vegas, Nevada, or, alternatively, have 16 indicated an intent to make such claims in the future (such as by way of the filing of 17 a separate lawsuit – now dismissed, by way of a letter of representation of counsel, 18 or by way of an evidence preservation letter from counsel). The Defendants are 19 residents of the County of Orange, State of California, and the residency of these 20 Defendants was identified to a court in a Complaint in the dismissed action G. 21 Castilla v. MGM, filed October 17, 2017, in the Los Angeles Superior Court 22 (“LASC”), case number BC679987. 23 149. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Marissa Castle is a resident of the State of California. Defendant has previously filed 25 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 26 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 27 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 28 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 39245596.3 -29- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 41 of 181 Page ID #:41 1 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 2 of the County of Los Angeles, State of California. 3 150. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Rebecca Castro is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 8 Los Angeles Superior Court (“LASC”), case number BC684047. 9 151. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Angela Catura is a resident of the State of California. Defendant has previously filed 11 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 12 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 13 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 14 Los Angeles Superior Court (“LASC”), case number BC684047. 15 152. Plaintiffs are informed and believe and thereon allege that Defendant 16 Christopher Caywood is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 153. Plaintiffs are informed and believe and thereon allege that Defendant 20 Kasandra Caywood is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 154. Plaintiffs are informed and believe and thereon allege that Defendant 24 Keri Cesario is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 155. Plaintiffs are informed and believe and thereon allege that Defendant 28 Robert Cesario is a resident of the State of California. Defendant has, through 39245596.3 -30- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 42 of 181 Page ID #:42 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 156. Plaintiffs are informed and believe and thereon allege that Defendant 4 Lauren Chagolla is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 157. Plaintiffs are informed and believe and thereon allege that Defendant 8 Tammy J. Chambers is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 158. Plaintiffs are informed and believe and thereon allege that Defendant 12 David Chatterton is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 159. Plaintiffs are informed and believe and thereon allege that Defendant 16 Marie Chatterton is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 160. Plaintiffs are informed and believe and thereon allege that Defendant 20 Veronica Chavez is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 161. Plaintiffs are informed and believe and thereon allege that Defendant 24 Kristi Christensen is a resident of the State of California, County of Los Angeles. 25 Defendant has, through counsel, asserted or threatened to assert claims against 26 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 27 162. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Fabiola Cintron is a resident of the State of California. Defendant has previously 39245596.3 -31- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 43 of 181 Page ID #:43 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 163. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Roger Cintron is a resident of the State of California. Defendant has previously filed 7 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 8 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 9 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 10 Los Angeles Superior Court (“LASC”), case number BC684047. 11 164. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Alisa Clawson is a resident of the State of California. Defendant has previously filed 13 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 165. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Kara Clement is a resident of the State of California. Defendant has previously filed 19 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 20 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 21 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 22 Los Angeles Superior Court (“LASC”), case number BC684047. 23 166. Plaintiffs are informed and believe and thereon allege that Defendant 24 Larissa Coburn is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 167. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Donna Cochrane is a resident of the State of California. Defendant has previously 39245596.3 -32- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 44 of 181 Page ID #:44 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 168. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Richard D. Coe is a resident of the State of California. Defendant has previously 7 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 8 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 9 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Gasper, et al. v. 10 MGM, filed November 20, 2017, in Los Angeles Superior Court (“LASC”), case 11 number BC684143, Plaintiffs are informed and believe that Defendant is a resident 12 of the County of Los Angeles, State of California. 13 169. Plaintiffs are informed and believe, and thereon allege, that defendant 14 David Cole is a resident of the State of California. Defendant has previously filed a 15 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 16 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 17 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 18 Los Angeles Superior Court (“LASC”), case number BC684047. 19 170. Plaintiffs are informed and believe and thereon allege that Defendant 20 Joseph Cole is a resident of the State of California. Defendant has, through counsel, 21 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 22 2017, shooting incident in Las Vegas, Nevada. 23 171. Plaintiffs are informed and believe and thereon allege that Defendant 24 Dennis Neal Coleman is a resident of the State of California. Defendant has, 25 through counsel, asserted or threatened to assert claims against Plaintiffs based upon 26 the October 1, 2017, shooting incident in Las Vegas, Nevada. 27 172. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Ronaldo Concepcion is a resident of the State of California. Defendant has 39245596.3 -33- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 45 of 181 Page ID #:45 1 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 2 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 3 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 4 Abraham, et al. v. MGM, filed November 20, 2017, in the Los Angeles Superior 5 Court (“LASC”), case number BC684047, Plaintiffs are informed and believe that 6 Defendant is a resident of the County of Los Angeles, State of California. 7 173. Plaintiffs are informed and believe and thereon allege that Defendant 8 Kathleen Conti is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 174. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Melissa Contri is a resident of the State of California. Defendant has previously filed 13 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 16 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 17 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 18 of the County of Los Angeles, State of California. 19 175. Plaintiffs are informed and believe and thereon allege that Defendant 20 Christa Conway is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 176. Plaintiffs are informed and believe and thereon allege that Defendant 24 William Cook is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 177. Plaintiffs are informed and believe and thereon allege that Defendant 28 Wendy Cooper is a resident of the State of California. Defendant has, through 39245596.3 -34- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 46 of 181 Page ID #:46 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 178. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Patricia Cope is a resident of the State of California. Defendant has previously filed 5 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 6 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 7 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 8 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Los Angeles, State of California. 11 179. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Jesse Cortez is a resident of the State of California. Defendant has previously filed a 13 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 180. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Lisa Cortez is a resident of the State of California. Defendant has previously filed a 19 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 20 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 21 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 22 Los Angeles Superior Court (“LASC”), case number BC684047. 23 181. Plaintiffs are informed and believe and thereon allege that Defendant 24 Douglas Corum is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 182. Plaintiffs are informed and believe and thereon allege that Defendant 28 Tyler Craig is a resident of the State of California, County of Los Angeles. 39245596.3 -35- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 47 of 181 Page ID #:47 1 Defendant has, through counsel, asserted or threatened to assert claims against 2 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 3 183. Plaintiffs are informed and believe and thereon allege that Defendant 4 Brenda Crane is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 184. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Brittani Crawford is a resident of the State of California. Defendant has previously 9 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 10 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 11 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 12 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 13 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 14 of the County of Los Angeles, State of California. 15 185. Plaintiffs are informed and believe and thereon allege that Defendant 16 Anthony M. Cresta is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 186. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Anthony Crisci is a resident of the State of California. Defendant has previously 21 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 22 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 23 in Las Vegas, Nevada, in Crisci v. MGM, filed November 15, 2017, in Clark County 24 District Court (“Clark County”), case number A-17-764709-C. 25 187. Plaintiffs are informed and believe and thereon allege that Defendant 26 Patricia Criss is a resident of the State of California, County of Los Angeles. 27 Defendant has, through counsel, asserted or threatened to assert claims against 28 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -36- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 48 of 181 Page ID #:48 1 188. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Kira M. Cross is a resident of the State of California. Defendant has previously filed 3 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 6 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 7 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 8 of the County of Santa Barbara, State of California. 9 189. Plaintiffs are informed and believe and thereon allege that Defendant 10 Joy M. Cruz is a resident of the State of California. Defendant has, through counsel, 11 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 12 2017, shooting incident in Las Vegas, Nevada. 13 190. Plaintiffs are informed and believe and thereon allege that Defendant 14 Jennifer Cuevas is a resident of the State of California, County of Los Angeles. 15 Defendant has, through counsel, asserted or threatened to assert claims against 16 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 17 191. Plaintiffs are informed and believe and thereon allege that Defendant 18 Adrianna Culler is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 192. Plaintiffs are informed and believe and thereon allege that Defendant 22 Marissa J. Currie is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 193. Plaintiffs are informed and believe and thereon allege that Defendant 26 Tammy Curtis is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -37- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 49 of 181 Page ID #:49 1 194. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Nicole Cusick is a resident of the State of California. Defendant has previously filed 3 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 195. Plaintiffs are informed and believe and thereon allege that Defendant 8 Robert Cusick is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 196. Plaintiffs are informed and believe and thereon allege that Defendant 12 Andrew Dahring is a resident of the State of California, County of Los Angeles. 13 Defendant has, through counsel, asserted or threatened to assert claims against 14 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 15 197. Plaintiffs are informed and believe and thereon allege that Defendant 16 Nancy Dahring is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 198. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Lisa Dancel is a resident of the State of California. Defendant has previously filed a 21 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada, in Dancel, et al. v. MGM, filed October 18, 2017, in the Los 24 Angeles Superior Court (“LASC”), case number BC680370. 25 199. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Lisa Marie Daniels is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -38- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 50 of 181 Page ID #:50 1 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 200. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Pritesh Davda is a resident of the State of California. Defendant has previously filed 5 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 6 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 7 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 8 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Los Angeles, State of California. 11 201. Plaintiffs are informed and believe and thereon allege that Defendant 12 Kyle David is a resident of the State of California, County of Los Angeles. 13 Defendant has, through counsel, asserted or threatened to assert claims against 14 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 15 202. Plaintiffs are informed and believe and thereon allege that Defendant 16 Jessica Davies is a resident of the State of California, County of Ventura. Defendant 17 has, through counsel, asserted or threatened to assert claims against Plaintiffs based 18 upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 19 203. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Ellen Davis is a resident of the State of California. Defendant has previously filed a 21 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 24 Los Angeles Superior Court (“LASC”), case number BC684047. 25 204. Plaintiffs are informed and believe and thereon allege that Defendant 26 Deborah Dawkins is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -39- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 51 of 181 Page ID #:51 1 205. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Deanna Dawson is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 206. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Lori Dawson is a resident of the State of California. Defendant has previously filed 9 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 10 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 11 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 12 Los Angeles Superior Court (“LASC”), case number BC684047. 13 207. Plaintiffs are informed and believe, and thereon allege that on October 14 1, 2017, decedent Thomas Day, Jr., was a resident of the State of California. 15 Plaintiffs are informed and believe and thereon allege that Defendants, the Estate of 16 Thomas Day, Jr., and Thomas Day, Sr. (surviving father, heir and successor-in17 interest to decedent), Kelsey Day (surviving daughter, heir and successor-in-interest 18 to decedent), Nolan Day (surviving son, heir and successor-in-interest to decedent) 19 and Whitney Day (surviving daughter, heir and successor-in-interest to decedent) 20 have, through counsel, made claims against Plaintiffs based upon the October 1, 21 2017, shooting incident in Las Vegas, Nevada, or, alternatively, have indicated an 22 intent to make such claims in the future (such as by way of the filing of a separate 23 lawsuit – now dismissed, by way of a letter of representation of counsel, or by way 24 of an evidence preservation letter from counsel). 25 208. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Cynthia Dearing is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -40- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 52 of 181 Page ID #:52 1 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 209. Plaintiffs are informed and believe and thereon allege that Defendant 4 Tamara Delameter is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 210. Plaintiffs are informed and believe and thereon allege that Defendant 8 Amy Delaplane is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 211. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Alejandra DeLaRosa is a resident of the State of California. Defendant has 13 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 14 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 15 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 16 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 17 BC684047. 18 212. Plaintiffs are informed and believe and thereon allege that Defendant 19 Brett DeLaura is a resident of the State of California. Defendant has, through 20 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 21 October 1, 2017, shooting incident in Las Vegas, Nevada. 22 213. Plaintiffs are informed and believe, and thereon allege, that defendant 23 Kortney Delaway is a resident of the State of California. Defendant has previously 24 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 25 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 26 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 27 Los Angeles Superior Court (“LASC”), case number BC684047. 28 39245596.3 -41- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 53 of 181 Page ID #:53 1 214. Plaintiffs are informed and believe and thereon allege that Defendant 2 Nicole Delgadillo is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 215. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Larry Delgado is a resident of the State of California. Defendant has previously filed 7 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 8 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 9 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 10 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 11 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 12 of the County of Los Angeles, State of California. 13 216. Plaintiffs are informed and believe and thereon allege that Defendant 14 Danielle Delira is a resident of the State of California, County of Los Angeles. 15 Defendant has, through counsel, asserted or threatened to assert claims against 16 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 17 217. Plaintiffs are informed and believe and thereon allege that Defendant 18 Nicole Desaracho is a resident of the State of California, County of Los Angeles. 19 Defendant has, through counsel, asserted or threatened to assert claims against 20 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 21 218. Plaintiffs are informed and believe and thereon allege that Defendant 22 Robert Di Nonno is a resident of the State of California, County of Ventura. 23 Defendant has, through counsel, asserted or threatened to assert claims against 24 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 219. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Mikaela Diaz is a resident of the State of California. Defendant has previously filed 27 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 28 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 39245596.3 -42- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 54 of 181 Page ID #:54 1 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 2 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 3 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 4 of the County of Ventura, State of California. 5 220. Plaintiffs are informed and believe and thereon allege that Defendant 6 Regina Dieringer is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 221. Plaintiffs are informed and believe and thereon allege that Defendant 10 Ryan Dieringer is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 222. Plaintiffs are informed and believe and thereon allege that Defendant 14 Diana J. Dimitruk is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 223. Plaintiffs are informed and believe and thereon allege that Defendant 18 Vanessa Dipolito is a resident of the State of California, County of Los Angeles. 19 Defendant has, through counsel, asserted or threatened to assert claims against 20 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 21 224. Plaintiffs are informed and believe and thereon allege that Defendant 22 Laura Dixon is a resident of the State of California, County of Ventura. Defendant 23 has, through counsel, asserted or threatened to assert claims against Plaintiffs based 24 upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 225. Plaintiffs are informed and believe and thereon allege that Defendant 26 Robyn Dobbs is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -43- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 55 of 181 Page ID #:55 1 226. Plaintiffs are informed and believe and thereon allege that Defendant 2 Daniel Dominguez is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 227. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Karin Donis is a resident of the State of California. Defendant has previously filed a 7 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 8 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 9 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 10 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 11 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 12 of the County of Los Angeles, State of California. 13 228. Plaintiffs are informed and believe and thereon allege that Defendant 14 Elyse Donnelly is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 229. Plaintiffs are informed and believe and thereon allege that Defendant 18 Kyle L. Donner is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 230. Plaintiffs are informed and believe and thereon allege that Defendant 22 Wendy A. Dormer is a resident of the State of California, County of Ventura. 23 Defendant has, through counsel, asserted or threatened to assert claims against 24 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 231. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Allison Dorr is a resident of the State of California. Defendant has previously filed a 27 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 28 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 39245596.3 -44- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 56 of 181 Page ID #:56 1 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 232. Plaintiffs are informed and believe and thereon allege that Defendant 4 Jessica Dovalina is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 233. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Julie Dove is a resident of the State of California. Defendant has previously filed a 9 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 10 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 11 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 12 Angeles Superior Court (“LASC”), case number BC687120. 13 234. Plaintiffs are informed and believe and thereon allege that Defendant 14 Eydie Doyle is a resident of the State of California. Defendant has, through counsel, 15 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 16 2017, shooting incident in Las Vegas, Nevada. 17 235. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Thomas Durell is a resident of the State of California. Defendant has previously 19 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 20 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 21 in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the 22 Los Angeles Superior Court (“LASC”), case number BC687120. 23 236. Plaintiffs are informed and believe and thereon allege that Defendant 24 Amber Durham is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 237. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Kendall Dusenberry is a resident of the State of California. Defendant has 39245596.3 -45- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 57 of 181 Page ID #:57 1 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 2 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 3 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 4 Mayfield, et al. v. MGM, filed December 15, 2017, in the Los Angeles Superior 5 Court (“LASC”), case number BC687120, Plaintiffs are informed and believe that 6 Defendant is a resident of the County of Los Angeles, State of California. 7 238. Plaintiffs are informed and believe and thereon allege that Defendant 8 Cheyenne Eberle is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 239. Plaintiffs are informed and believe and thereon allege that Defendant 12 Gena Elfelt is a resident of the State of California. Defendant has, through counsel, 13 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 14 2017, shooting incident in Las Vegas, Nevada. 15 240. Plaintiffs are informed and believe and thereon allege that Defendant 16 Derrick Elliott is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 241. Plaintiffs are informed and believe and thereon allege that Defendant 20 Jillian Elliott is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 242. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Staci Ellis is a resident of the State of California. Defendant has previously filed a 25 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 26 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 27 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 28 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 39245596.3 -46- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 58 of 181 Page ID #:58 1 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 2 of the County of Los Angeles, State of California. 3 243. Plaintiffs are informed and believe and thereon allege that Defendant 4 Steve Encinias is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 244. Plaintiffs are informed and believe and thereon allege that Defendant 8 Shanyce English is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 245. Plaintiffs are informed and believe and thereon allege that Defendant 12 Madelyn Enochs is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 246. Plaintiffs are informed and believe and thereon allege that Defendant 16 Candice Erickson is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 247. Plaintiffs are informed and believe and thereon allege that Defendant 20 Chris Erickson is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 248. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Kandis Erickson is a resident of the State of California. Defendant has previously 25 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 26 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 27 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 28 Los Angeles Superior Court (“LASC”), case number BC684047. 39245596.3 -47- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 59 of 181 Page ID #:59 1 249. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Sabrina Esparza is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 250. Plaintiffs are informed and believe and thereon allege that Defendant 8 Ernesto Espinoza is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 251. Plaintiffs are informed and believe and thereon allege that Defendant 12 Soraya M. Espinoza is a resident of the State of California, County of Los Angeles. 13 Defendant has, through counsel, asserted or threatened to assert claims against 14 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 15 252. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Laura Estrada is a resident of the State of California. Defendant has previously filed 17 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 18 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 19 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 20 Los Angeles Superior Court (“LASC”), case number BC684047. 21 253. Plaintiffs are informed and believe and thereon allege that Defendant 22 Nico Estrada is a resident of the State of California, County of Los Angeles. 23 Defendant has, through counsel, asserted or threatened to assert claims against 24 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 254. Plaintiffs are informed and believe, and thereon allege that on October 26 1, 2017, decedent Stacee Etcheber, was a resident of the State of California. 27 Plaintiffs are informed and believe and thereon allege that Defendants, the Estate of 28 Stacee Etcheber and Vincent Etcheber (surviving husband, heir and successor-in39245596.3 -48- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 60 of 181 Page ID #:60 1 interest) have, through counsel, made claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada, or, alternatively, have 3 indicated an intent to make such claims in the future (such as by way of the filing of 4 a separate lawsuit – now dismissed, by way of a letter of representation of counsel, 5 or by way of an evidence preservation letter from counsel). 6 255. Plaintiffs are informed and believe and thereon allege that Defendant 7 Briana Evans is a resident of the State of California. Defendant has, through 8 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 9 October 1, 2017, shooting incident in Las Vegas, Nevada. 10 256. Plaintiffs are informed and believe, and thereon allege, that defendant 11 Cynthia Evans is a resident of the State of California. Defendant has previously filed 12 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 13 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 14 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 15 Los Angeles Superior Court (“LASC”), case number BC684047. 16 257. Plaintiffs are informed and believe, and thereon allege, that defendant 17 Dennis Evans is a resident of the State of California. Defendant has previously filed 18 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 19 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 20 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 21 Los Angeles Superior Court (“LASC”), case number BC684047. 22 258. Plaintiffs are informed and believe and thereon allege that Defendant 23 Wendy Everett is a resident of the State of California. Defendant has, through 24 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 25 October 1, 2017, shooting incident in Las Vegas, Nevada. 26 259. Plaintiffs are informed and believe, and thereon allege, that defendant 27 Kyle Evinger is a resident of the State of California. Defendant has previously filed 28 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 39245596.3 -49- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 61 of 181 Page ID #:61 1 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 2 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 3 Los Angeles Superior Court (“LASC”), case number BC684047. 4 260. Plaintiffs are informed and believe and thereon allege that Defendant 5 Ashley Fargo is a resident of the State of California. Defendant has, through 6 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 7 October 1, 2017, shooting incident in Las Vegas, Nevada. 8 261. Plaintiffs are informed and believe, and thereon allege, that defendant 9 Michelle Farias is a resident of the State of California. Defendant has previously 10 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 11 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 12 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 13 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 14 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 15 of the County of Los Angeles, State of California. 16 262. Plaintiffs are informed and believe, and thereon allege, that defendant 17 Angela Favia is a resident of the State of California. Defendant has previously filed 18 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 19 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 20 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 21 Los Angeles Superior Court (“LASC”), case number BC684047. 22 263. Plaintiffs are informed and believe, and thereon allege, that defendant 23 Jeffrey Feig is a resident of the State of California. Defendant has previously filed a 24 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 25 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 26 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 27 Los Angeles Superior Court (“LASC”), case number BC684047. 28 39245596.3 -50- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 62 of 181 Page ID #:62 1 264. Plaintiffs are informed and believe and thereon allege that Defendant 2 Rafael Feliciano is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 265. Plaintiffs are informed and believe and thereon allege that Defendant 6 Lauren Ferguson is a resident of the State of California, County of Los Angeles. 7 Defendant has, through counsel, asserted or threatened to assert claims against 8 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 9 266. Plaintiffs are informed and believe and thereon allege that Defendant 10 Jennie Fernandes is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 267. Plaintiffs are informed and believe and thereon allege that Defendant 14 Maryssa Fields is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 268. Plaintiffs are informed and believe and thereon allege that Defendant 18 Melissa Fierro is a resident of the State of California, County of Los Angeles. 19 Defendant has, through counsel, asserted or threatened to assert claims against 20 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 21 269. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Baylee Fincher is a resident of the State of California. Defendant has previously 23 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 24 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 25 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 26 Los Angeles Superior Court (“LASC”), case number BC684047. 27 270. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Brooke Fincher is a resident of the State of California. Defendant has previously 39245596.3 -51- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 63 of 181 Page ID #:63 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 271. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Mindy Fincher is a resident of the State of California. Defendant has previously 7 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 8 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 9 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 10 Los Angeles Superior Court (“LASC”), case number BC684047. 11 272. Plaintiffs are informed and believe and thereon allege that Defendant 12 Austin Fisher is a resident of the State of California, County of Santa Barbara. 13 Defendant has, through counsel, asserted or threatened to assert claims against 14 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 15 273. Plaintiffs are informed and believe and thereon allege that Defendant 16 Lyndsay Fisher is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 274. Plaintiffs are informed and believe and thereon allege that Defendant 20 Susan Fitzgerald is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 275. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Emily Flesher is a resident of the State of California. Defendant has previously filed 25 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 26 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 27 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 28 Los Angeles Superior Court (“LASC”), case number BC684047. 39245596.3 -52- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 64 of 181 Page ID #:64 1 276. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Kristi Flesher is a resident of the State of California. Defendant has previously filed 3 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 277. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Art Flores is a resident of the State of California. Defendant has previously filed a 9 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 10 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 11 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 12 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 13 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 14 of the County of Los Angeles, State of California. 15 278. Plaintiffs are informed and believe and thereon allege that Defendant 16 Daniel Flores is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 279. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Steven Flores is a resident of the State of California. Defendant has previously filed 21 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 24 Angeles Superior Court (“LASC”), case number BC687120. 25 280. Plaintiffs are informed and believe and thereon allege that Defendant 26 Jennifer Fluegal is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -53- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 65 of 181 Page ID #:65 1 281. Plaintiffs are informed and believe and thereon allege that Defendant 2 Marlana Foltz is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 282. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Donald Forsyth is a resident of the State of California. Defendant has previously 7 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 8 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 9 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 10 Los Angeles Superior Court (“LASC”), case number BC684047. 11 283. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Rochelle Forsyth is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 284. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Kadedra Fowler is a resident of the State of California. Defendant has previously 19 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 20 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 21 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 22 Los Angeles Superior Court (“LASC”), case number BC684047. 23 285. Plaintiffs are informed and believe and thereon allege that Defendant 24 Justin Frame is a resident of the State of California. Defendant has, through counsel, 25 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 26 2017, shooting incident in Las Vegas, Nevada. 27 286. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Brittany Friend is a resident of the State of California. Defendant has previously 39245596.3 -54- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 66 of 181 Page ID #:66 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 287. Plaintiffs are informed and believe and thereon allege that Defendant 6 Cynthia Friske is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 288. Plaintiffs are informed and believe and thereon allege that Defendant 10 Amanda Frost is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 289. Plaintiffs are informed and believe and thereon allege that Defendant 14 Bobbi Frye is a resident of the State of California. Defendant has, through counsel, 15 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 16 2017, shooting incident in Las Vegas, Nevada. 17 290. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Lorraine Fuentes is a resident of the State of California. Defendant has previously 19 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 20 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 21 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 22 Los Angeles Superior Court (“LASC”), case number BC684047. 23 291. Plaintiffs are informed and believe and thereon allege that Defendant 24 April Gabany is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 292. Plaintiffs are informed and believe and thereon allege that Defendant 28 Tina Galarza is a resident of the State of California. Defendant has, through 39245596.3 -55- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 67 of 181 Page ID #:67 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 293. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Erica Gallegos is a resident of the State of California. Defendant has previously filed 5 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 6 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 7 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 8 Los Angeles Superior Court (“LASC”), case number BC684047. 9 294. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Mandy Gallegos is a resident of the State of California. Defendant has previously 11 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 12 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 13 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 14 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 15 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 16 of the County of Los Angeles, State of California. 17 295. Plaintiffs are informed and believe and thereon allege that Defendant 18 Stephanie Gallegos is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 296. Plaintiffs are informed and believe, and thereon allege that on October 22 1, 2017, decedent Keri Galvan, was a resident of the State of California. Plaintiffs 23 are informed and believe and thereon allege that Defendants, the Estate of Keri 24 Galvan, Justin Galvan (surviving spouse, heir, and successor-in-interest to 25 decedent), R.G. (a minor), P.G. (a minor), and P.G. (a minor), have, through 26 counsel, made claims against Plaintiffs based upon the October 1, 2017, shooting 27 incident in Las Vegas, Nevada, or, alternatively, have indicated an intent to make 28 such claims in the future (such as by way of the filing of a separate lawsuit – now 39245596.3 -56- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 68 of 181 Page ID #:68 1 dismissed, by way of a letter of representation of counsel, or by way of an evidence 2 preservation letter from counsel). The Defendants are residents of the County of Los 3 Angeles, State of California and the residency of these Defendants was identified to 4 a court in a Complaint in the dismissed action Galvan, et al. v. Live Nation, filed 5 December 7, 2017, in the Los Angeles Superior Court (“LASC”), case number 6 BC686248. 7 297. Plaintiffs are informed and believe and thereon allege that Defendant 8 Celena Garcia is a resident of the State of California, County of Los Angeles. 9 Defendant has, through counsel, asserted or threatened to assert claims against 10 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 11 298. Plaintiffs are informed and believe and thereon allege that Defendant 12 Christina Garcia is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 299. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Eric Garcia is a resident of the State of California. Defendant has previously filed a 17 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 18 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 19 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 20 Los Angeles Superior Court (“LASC”), case number BC684047. 21 300. Plaintiffs are informed and believe and thereon allege that Defendant 22 Eugene Garcia is a resident of the State of California, County of Ventura. 23 Defendant has, through counsel, asserted or threatened to assert claims against 24 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 301. Plaintiffs are informed and believe and thereon allege that Defendant 26 Randy Garcia is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -57- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 69 of 181 Page ID #:69 1 302. Plaintiffs are informed and believe and thereon allege that Defendant 2 Stacy Garcia is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 303. Plaintiffs are informed and believe and thereon allege that Defendant 6 Teresa Garcia is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 304. Plaintiffs are informed and believe and thereon allege that Defendant 10 Laura Gardhouse is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 305. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Ellenor Gargano is a resident of the State of California. Defendant has previously 15 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 16 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 17 in Las Vegas, Nevada, in Gargano v. Mandalay Bay, filed February 2, 2018, in 18 Clark County District Court (“Clark County”), case number A-18-768832-C. 19 306. Plaintiffs are informed and believe and thereon allege that Defendant 20 Jose L. Garza is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 307. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Paige Gasper is a resident of the State of California. Defendant has previously filed 25 two lawsuits (which were subsequently voluntarily dismissed) against one or more 26 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 27 in Las Vegas, Nevada, in Gasper v. MGM, filed October 10, 2017, in Clark County 28 District Court (“Clark County”), case number A-17-762858, and in Gasper, et al. v. 39245596.3 -58- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 70 of 181 Page ID #:70 1 MGM, filed November 20, 2017, in Los Angeles Superior Court (“LASC”), case 2 number BC684143. 3 308. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Brittany Gebhart is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 8 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Ventura, State of California. 11 309. Plaintiffs are informed and believe, and thereon allege, that defendant 12 William Georgia is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 16 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 17 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 18 of the County of Los Angeles, State of California. 19 310. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Garrett Ghahyasi is a resident of the State of California. Defendant has previously 21 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 22 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 23 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 24 Los Angeles Superior Court (“LASC”), case number BC684047. 25 311. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Meilin Gibbens is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -59- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 71 of 181 Page ID #:71 1 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 2 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 3 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 4 of the County of Los Angeles, State of California. 5 312. Plaintiffs are informed and believe and thereon allege that Defendant 6 Erin Gill is a resident of the State of California. Defendant has, through counsel, 7 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 8 2017, shooting incident in Las Vegas, Nevada. 9 313. Plaintiffs are informed and believe and thereon allege that Defendant 10 John Gilmore is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 314. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Kylee Glasscock is a resident of the State of California. Defendant has previously 15 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 16 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 17 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 18 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 19 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 20 of the County of Ventura, State of California. 21 315. Plaintiffs are informed and believe and thereon allege that Defendant 22 Robert Glavis is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 316. Plaintiffs are informed and believe and thereon allege that Defendant 26 Teresa Glavis is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -60- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 72 of 181 Page ID #:72 1 317. Plaintiffs are informed and believe and thereon allege that Defendant 2 Tristi Glover is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 318. Plaintiffs are informed and believe and thereon allege that Defendant 6 Michell Goble is a resident of the State of California, County of Los Angeles. 7 Defendant has, through counsel, asserted or threatened to assert claims against 8 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 9 319. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Michelle Gomes is a resident of the State of California. Defendant has previously 11 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 12 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 13 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 14 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 15 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 16 of the County of Los Angeles, State of California. 17 320. Plaintiffs are informed and believe and thereon allege that Defendant 18 Ashley Gomez is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 321. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Julie Gomez is a resident of the State of California. Defendant has previously filed a 23 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 24 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 25 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 26 Angeles Superior Court (“LASC”), case number BC687120. 27 322. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Steven Gomez is a resident of the State of California. Defendant has previously filed 39245596.3 -61- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 73 of 181 Page ID #:73 1 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 2 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 3 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 4 Angeles Superior Court (“LASC”), case number BC687120. 5 323. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Jeffrey Alan Gonsalves is a resident of the State of California. Defendant has 7 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 8 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 9 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 10 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 11 BC684047. 12 324. Plaintiffs are informed and believe and thereon allege that Defendant 13 Andrea Gonzales is a resident of the State of California, County of Los Angeles. 14 Defendant has, through counsel, asserted or threatened to assert claims against 15 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 16 325. Plaintiffs are informed and believe and thereon allege that Defendant 17 Daniel Joseph Gonzales is a resident of the State of California, County of Ventura. 18 Defendant has, through counsel, asserted or threatened to assert claims against 19 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 20 326. Plaintiffs are informed and believe and thereon allege that Defendant 21 Alesha Gonzalez is a resident of the State of California, County of Los Angeles. 22 Defendant has, through counsel, asserted or threatened to assert claims against 23 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 24 327. Plaintiffs are informed and believe and thereon allege that Defendant 25 Jesus Vincent Gonzalez is a resident of the State of California, County of Los 26 Angeles. Defendant has, through counsel, asserted or threatened to assert claims 27 against Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, 28 Nevada. 39245596.3 -62- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 74 of 181 Page ID #:74 1 328. Plaintiffs are informed and believe and thereon allege that Defendant 2 Michael Gonzalez is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 329. Plaintiffs are informed and believe and thereon allege that Defendant 6 Michael Goodnight is a resident of the State of California, County of Los Angeles. 7 Defendant has, through counsel, asserted or threatened to assert claims against 8 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 9 330. Plaintiffs are informed and believe and thereon allege that Defendant 10 Doreen Gorman is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 331. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Delores Gray is a resident of the State of California. Defendant has previously filed 15 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 16 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 17 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 18 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 19 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 20 of the County of Los Angeles, State of California. 21 332. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Jeanette Gray is a resident of the State of California. Defendant has previously filed 23 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 24 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 25 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 26 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 27 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 28 of the County of Los Angeles, State of California. 39245596.3 -63- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 75 of 181 Page ID #:75 1 333. Plaintiffs are informed and believe and thereon allege that Defendant 2 Nicole Gray is a resident of the State of California. Defendant has, through counsel, 3 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 4 2017, shooting incident in Las Vegas, Nevada. 5 334. Plaintiffs are informed and believe and thereon allege that Defendant 6 Regina Green is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 335. Plaintiffs are informed and believe and thereon allege that Defendant 10 David J. Grijalba Jr. is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 336. Plaintiffs are informed and believe and thereon allege that Defendant 14 Jennifer Grimm is a resident of the State of California, County of Los Angeles. 15 Defendant has, through counsel, asserted or threatened to assert claims against 16 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 17 337. Plaintiffs are informed and believe and thereon allege that Defendant 18 Gabriel Guerrero is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 338. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Miguel Guerrero is a resident of the State of California. Defendant has previously 23 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 24 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 25 in Las Vegas, Nevada, in Spencer, et al. v. Paddock, filed October 17, 2017, in Los 26 Angeles Superior Court (“LASC”), case number BC680065. 27 339. Plaintiffs are informed and believe and thereon allege that Defendant 28 Mikerra Guerrero is a resident of the State of California. Defendant has, through 39245596.3 -64- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 76 of 181 Page ID #:76 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 340. Plaintiffs are informed and believe and thereon allege that Defendant 4 Trisha Guerrero is a resident of the State of California, County of Los Angeles. 5 Defendant has, through counsel, asserted or threatened to assert claims against 6 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 7 341. Plaintiffs are informed and believe, and thereon allege that on October 8 1, 2017, decedent Rocio Guillen, was a resident of the State of California. Plaintiffs 9 are informed and believe and thereon allege that Defendants, the Estate of Rocio 10 Guillen, Christopher Jaksha (successor-in-interest to decedent), S.J. (a minor, 11 successor-in-interest), and A.J. (a minor, and successor-in-interest), who have, 12 through counsel, made claims against Plaintiffs based upon the October 1, 2017, 13 shooting incident in Las Vegas, Nevada, or, alternatively, have indicated an intent to 14 make such claims in the future (such as by way of the filing of a separate lawsuit – 15 now dismissed, by way of a letter of representation of counsel, or by way of an 16 evidence preservation letter from counsel). The Defendants are residents of the 17 County of Riverside, State of California and the residency of these Defendants was 18 identified to a court in a Complaint in the dismissed action Jaksha, et al. v. MGM, 19 filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 20 number BC684048. 21 342. Plaintiffs are informed and believe and thereon allege that Defendant 22 Thomas Gunderson is a resident of the State of California, County of Los Angeles. 23 Defendant has, through counsel, asserted or threatened to assert claims against 24 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 343. Plaintiffs are informed and believe and thereon allege that Defendant 26 Tammy Hiscox Gurule is a resident of the State of California. Defendant has, 27 through counsel, asserted or threatened to assert claims against Plaintiffs based upon 28 the October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -65- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 77 of 181 Page ID #:77 1 344. Plaintiffs are informed and believe and thereon allege that Defendant 2 Tammy M. Gurule is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 345. Plaintiffs are informed and believe and thereon allege that Defendant 6 Kimberly Gutierrez is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 346. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Crystal Hadley is a resident of the State of California. Defendant has previously 11 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 12 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 13 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 14 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 15 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 16 of the County of Los Angeles, State of California. 17 347. Plaintiffs are informed and believe and thereon allege that Defendant 18 Deborah Hall is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 348. Plaintiffs are informed and believe and thereon allege that Defendant 22 Steven Hall is a resident of the State of California. Defendant has, through counsel, 23 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 24 2017, shooting incident in Las Vegas, Nevada. 25 349. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Travis Hall is a resident of the State of California. Defendant has previously filed a 27 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 28 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 39245596.3 -66- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 78 of 181 Page ID #:78 1 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 350. Plaintiffs are informed and believe and thereon allege that Defendant 4 Michelle Hamel is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 351. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Kiersten Harling is a resident of the State of California. Defendant has previously 9 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 10 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 11 in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the 12 Los Angeles Superior Court (“LASC”), case number BC687120. 13 352. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Simon Harling is a resident of the State of California. Defendant has previously filed 15 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 16 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 17 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 18 Angeles Superior Court (“LASC”), case number BC687120. 19 353. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Brandon Harlow is a resident of the State of California. Defendant has previously 21 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 22 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 23 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 24 Los Angeles Superior Court (“LASC”), case number BC684047. 25 354. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Regina Anne Harris is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -67- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 79 of 181 Page ID #:79 1 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 355. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Lisa Hartz is a resident of the State of California. Defendant has previously filed a 5 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 6 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 7 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 8 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Ventura, State of California. 11 356. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Melinda Hawkins is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 357. Plaintiffs are informed and believe and thereon allege that Defendant 18 Breanna Hayden is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 358. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Kiley Hayden is a resident of the State of California. Defendant has previously filed 23 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 24 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 25 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 26 Los Angeles Superior Court (“LASC”), case number BC684047. 27 359. Plaintiffs are informed and believe and thereon allege that Defendant 28 Kristina Hayden is a resident of the State of California. Defendant has, through 39245596.3 -68- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 80 of 181 Page ID #:80 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 360. Plaintiffs are informed and believe and thereon allege that Defendant 4 Larry Hayden is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 361. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Cori Haynes is a resident of the State of California. Defendant has previously filed a 9 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 10 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 11 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 12 Los Angeles Superior Court (“LASC”), case number BC684047. 13 362. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Bryce Heathcoat is a resident of the State of California. Defendant has previously 15 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 16 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 17 in Las Vegas, Nevada, in Dancel, et al. v. MGM, filed October 18, 2017, in the Los 18 Angeles Superior Court (“LASC”), case number BC680370. 19 363. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Jennifer Heidt is a resident of the State of California. Defendant has previously filed 21 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 24 Los Angeles Superior Court (“LASC”), case number BC684047. 25 364. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Steven Heirshberg is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -69- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 81 of 181 Page ID #:81 1 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 2 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 3 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 4 of the County of Los Angeles, State of California. 5 365. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Wendy Heirshberg is a resident of the State of California. Defendant has previously 7 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 8 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 9 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 10 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 11 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 12 of the County of Los Angeles, State of California. 13 366. Plaintiffs are informed and believe and thereon allege that Defendant 14 Brandon Helmick is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 367. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Justin Henderson is a resident of the State of California. Defendant has previously 19 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 20 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 21 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 22 Los Angeles Superior Court (“LASC”), case number BC684047. 23 368. Plaintiffs are informed and believe and thereon allege that Defendant 24 Kristine Henderson is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 369. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Andrea Henning is a resident of the State of California. Defendant has previously 39245596.3 -70- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 82 of 181 Page ID #:82 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 370. Plaintiffs are informed and believe and thereon allege that Defendant 6 Justin Heredia is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 371. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Heather Hernandez is a resident of the State of California. Defendant has previously 11 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 12 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 13 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 14 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 15 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 16 of the County of Los Angeles, State of California. 17 372. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Rebecca Hernandez is a resident of the State of California. Defendant has previously 19 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 20 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 21 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 22 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 23 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 24 of the County of Los Angeles, State of California. 25 373. Plaintiffs are informed and believe and thereon allege that Defendant 26 Ricardo Hernandez is a resident of the State of California, County of Los Angeles. 27 Defendant has, through counsel, asserted or threatened to assert claims against 28 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -71- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 83 of 181 Page ID #:83 1 374. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Emmitt Hickman is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 375. Plaintiffs are informed and believe and thereon allege that Defendant 8 Eric Higgins is a resident of the State of California. Defendant has, through counsel, 9 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 10 2017, shooting incident in Las Vegas, Nevada. 11 376. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Diane Hill is a resident of the State of California. Defendant has previously filed a 13 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada, in Hill v. MGM, filed February 12, 2018, in Clark County 16 District Court (“Clark County”), case number A-18-769385-C. 17 377. Plaintiffs are informed and believe and thereon allege that Defendant 18 Tyler Hill is a resident of the State of California. Defendant has, through counsel, 19 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 20 2017, shooting incident in Las Vegas, Nevada. 21 378. Plaintiffs are informed and believe and thereon allege that Defendant 22 Teresa Himley is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 379. Plaintiffs are informed and believe and thereon allege that Defendant 26 Jeff Hines is a resident of the State of California. Defendant has, through counsel, 27 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 28 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -72- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 84 of 181 Page ID #:84 1 380. Plaintiffs are informed and believe and thereon allege that Defendant 2 Whitney Linn Hinnant is a resident of the State of California. Defendant has, 3 through counsel, asserted or threatened to assert claims against Plaintiffs based upon 4 the October 1, 2017, shooting incident in Las Vegas, Nevada. 5 381. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Lauren Hitt is a resident of the State of California. Defendant has previously filed a 7 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 8 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 9 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 10 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 11 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 12 of the County of Los Angeles, State of California. 13 382. Plaintiffs are informed and believe and thereon allege that Defendant 14 Kendra Hobbs is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 383. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Patrick Hobbs is a resident of the State of California. Defendant has previously filed 19 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 20 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 21 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 22 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 23 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 24 of the County of Los Angeles, State of California. 25 384. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Leigh Ann Hodgson is a resident of the State of California. Defendant has 27 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 28 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 39245596.3 -73- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 85 of 181 Page ID #:85 1 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 2 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 3 BC684047. 4 385. Plaintiffs are informed and believe and thereon allege that Defendant 5 Katherine Hoey is a resident of the State of California. Defendant has, through 6 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 7 October 1, 2017, shooting incident in Las Vegas, Nevada. 8 386. Plaintiffs are informed and believe and thereon allege that Defendant 9 Bryan Hoffrichter is a resident of the State of California. Defendant has, through 10 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 11 October 1, 2017, shooting incident in Las Vegas, Nevada. 12 387. Plaintiffs are informed and believe and thereon allege that Defendant 13 Donna Holden is a resident of the State of California. Defendant has, through 14 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 15 October 1, 2017, shooting incident in Las Vegas, Nevada. 16 388. Plaintiffs are informed and believe, and thereon allege, that defendant 17 Tanna Holderle is a resident of the State of California. Defendant has previously 18 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 19 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 20 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 21 Los Angeles Superior Court (“LASC”), case number BC684047. 22 389. Plaintiffs are informed and believe and thereon allege that Defendant 23 Albert Holguin is a resident of the State of California. Defendant has, through 24 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 25 October 1, 2017, shooting incident in Las Vegas, Nevada. 26 390. Plaintiffs are informed and believe and thereon allege that Defendant 27 Cindy Holguin is a resident of the State of California. Defendant has, through 28 39245596.3 -74- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 86 of 181 Page ID #:86 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 391. Plaintiffs are informed and believe and thereon allege that Defendant 4 Lisa Holguin is a resident of the State of California. Defendant has, through counsel, 5 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 6 2017, shooting incident in Las Vegas, Nevada. 7 392. Plaintiffs are informed and believe, and thereon allege, that defendant 8 John Holladay is a resident of the State of California. Defendant has previously filed 9 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 10 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 11 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 12 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 13 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 14 of the County of Ventura, State of California. 15 393. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Melissa Holmquist is a resident of the State of California. Defendant has previously 17 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 18 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 19 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 20 Los Angeles Superior Court (“LASC”), case number BC684047. 21 394. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Vanessa Holub is a resident of the State of California. Defendant has previously 23 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 24 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 25 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 26 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 27 number BC684047. 28 39245596.3 -75- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 87 of 181 Page ID #:87 1 395. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Alexis Hood is a resident of the State of California. Defendant has previously filed a 3 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 396. Plaintiffs are informed and believe and thereon allege that Defendant 8 Taylor Hood is a resident of the State of California. Defendant has, through counsel, 9 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 10 2017, shooting incident in Las Vegas, Nevada. 11 397. Plaintiffs are informed and believe and thereon allege that Defendant 12 Brendan Hoolihan is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 398. Plaintiffs are informed and believe and thereon allege that Defendant 16 Brittany Hopkins is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 399. Plaintiffs are informed and believe and thereon allege that Defendant 20 Michelle Howlett is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 400. Plaintiffs are informed and believe and thereon allege that Defendant 24 Malisa Hoyme is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 401. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Debra Hudson is a resident of the State of California. Defendant has previously filed 39245596.3 -76- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 88 of 181 Page ID #:88 1 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 2 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 3 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 402. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Leanne Huggins is a resident of the State of California. Defendant has previously 7 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 8 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 9 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Huggins, et al. v. 10 MGM, filed February 14, 2018, in the Los Angeles Superior Court (“LASC”), case 11 number BC694788, Plaintiffs are informed and believe that Defendant is a resident 12 of the County of Los Angeles, State of California. 13 403. Plaintiffs are informed and believe and thereon allege that Defendant 14 Laurie Hulbert is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 404. Plaintiffs are informed and believe and thereon allege that Defendant 18 Julie Huntsinger is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 405. Plaintiffs are informed and believe and thereon allege that Defendant 22 Ryan Huntsinger is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 406. Plaintiffs are informed and believe and thereon allege that Defendant 26 Taylor Hurwit is a resident of the State of California, County of Los Angeles. 27 Defendant has, through counsel, asserted or threatened to assert claims against 28 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -77- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 89 of 181 Page ID #:89 1 407. Plaintiffs are informed and believe and thereon allege that Defendant 2 Bret Ivey is a resident of the State of California, County of Los Angeles. Defendant 3 has, through counsel, asserted or threatened to assert claims against Plaintiffs based 4 upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 5 408. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Alicia Jackson is a resident of the State of California. Defendant has previously filed 7 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 8 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 9 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 10 Los Angeles Superior Court (“LASC”), case number BC684047. 11 409. Plaintiffs are informed and believe and thereon allege that Defendant 12 Thomas S. Jacobus is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 410. Plaintiffs are informed and believe and thereon allege that Defendant 16 Philip Jardell is a resident of the State of California, County of Los Angeles. 17 Defendant has, through counsel, asserted or threatened to assert claims against 18 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 19 411. Plaintiffs are informed and believe and thereon allege that Defendant 20 Joanna Jashimoto is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 412. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Aaron E. Jenkins is a resident of the State of California. Defendant has previously 25 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 26 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 27 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 28 Los Angeles Superior Court (“LASC”), case number BC684047. 39245596.3 -78- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 90 of 181 Page ID #:90 1 413. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Jessica Ann Jenkins is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 414. Plaintiffs are informed and believe and thereon allege that Defendant 8 Teresa Jensen is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 415. Plaintiffs are informed and believe and thereon allege that Defendant 12 Miranda Jessen is a resident of the State of California, County of Los Angeles. 13 Defendant has, through counsel, asserted or threatened to assert claims against 14 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 15 416. Plaintiffs are informed and believe and thereon allege that Defendant 16 Sarah Jick is a resident of the State of California, County of Los Angeles. 17 Defendant has, through counsel, asserted or threatened to assert claims against 18 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 19 417. Plaintiffs are informed and believe and thereon allege that Defendant 20 Renee Jimenez is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 418. Plaintiffs are informed and believe, and thereon allege, that defendant 24 LaNeshia Johnson is a resident of the State of California. Defendant has previously 25 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 26 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 27 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 28 Los Angeles Superior Court (“LASC”), case number BC684047. 39245596.3 -79- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 91 of 181 Page ID #:91 1 419. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Monta Johnson is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 420. Plaintiffs are informed and believe and thereon allege that Defendant 8 Michelle Jones is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 421. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Misty Jones is a resident of the State of California. Defendant has previously filed a 13 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 16 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 17 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 18 of the County of Los Angeles, State of California. 19 422. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Rob Jones is a resident of the State of California. Defendant has previously filed a 21 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 24 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 25 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 26 of the County of Ventura, State of California. 27 423. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Shaheed Jones is a resident of the State of California. Defendant has previously filed 39245596.3 -80- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 92 of 181 Page ID #:92 1 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 2 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 3 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 4 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 5 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 6 of the County of Los Angeles, State of California. 7 424. Plaintiffs are informed and believe and thereon allege that Defendant 8 Clarice Kahia is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 425. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Ted Kalnas is a resident of the State of California. Defendant has previously filed a 13 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada. Based on the allegations in that lawsuit, Vanderstay, et al. v. 16 MGM, filed November 13, 2017, in the Los Angeles Superior Court (“LASC”), 17 Plaintiffs are informed and believe that Defendant is a resident of the County of Los 18 Angeles, State of California. 19 426. Plaintiffs are informed and believe and thereon allege that Defendant 20 Lori Kammer is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 427. Plaintiffs are informed and believe and thereon allege that Defendant 24 Todd Kammer is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 428. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Michael Kaplish is a resident of the State of California. Defendant has previously 39245596.3 -81- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 93 of 181 Page ID #:93 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 4 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 5 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 6 of the County of Ventura, State of California. 7 429. Plaintiffs are informed and believe and thereon allege that Defendant 8 Mirta Katnich is a resident of the State of California, County of Los Angeles. 9 Defendant has, through counsel, asserted or threatened to assert claims against 10 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 11 430. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Scott Keeran is a resident of the State of California. Defendant has previously filed a 13 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 431. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Valerie Melissa Keeran is a resident of the State of California. Defendant has 19 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 20 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 21 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 22 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 23 BC684047. 24 432. Plaintiffs are informed and believe and thereon allege that Defendant 25 Alaina Kelly is a resident of the State of California. Defendant has, through 26 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 27 October 1, 2017, shooting incident in Las Vegas, Nevada. 28 39245596.3 -82- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 94 of 181 Page ID #:94 1 433. Plaintiffs are informed and believe and thereon allege that Defendant 2 Debra Kelly is a resident of the State of California. Defendant has, through counsel, 3 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 4 2017, shooting incident in Las Vegas, Nevada. 5 434. Plaintiffs are informed and believe and thereon allege that Defendant 6 William M. Kelly is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 435. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Kyle Kennedy is a resident of the State of California. Defendant has previously filed 11 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 12 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 13 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 14 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 15 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 16 of the County of Los Angeles, State of California. 17 436. Plaintiffs are informed and believe and thereon allege that Defendant 18 Brenda Kent is a resident of the State of California, County of Los Angeles. 19 Defendant has, through counsel, asserted or threatened to assert claims against 20 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 21 437. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Kelsi Kessler is a resident of the State of California. Defendant has previously filed 23 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 24 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 25 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 26 Los Angeles Superior Court (“LASC”), case number BC684047. 27 438. Plaintiffs are informed and believe and thereon allege that Defendant 28 Brian Kettering is a resident of the State of California. Defendant has, through 39245596.3 -83- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 95 of 181 Page ID #:95 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 439. Plaintiffs are informed and believe and thereon allege that Defendant 4 Yvette Kettering is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 440. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Sana Khader is a resident of the State of California. Defendant has previously filed a 9 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 10 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 11 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 12 Los Angeles Superior Court (“LASC”), case number BC684047. 13 441. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Joanna Kilma is a resident of the State of California. Defendant has previously filed 15 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 16 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 17 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 18 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 19 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 20 of the County of Los Angeles, State of California. 21 442. Plaintiffs are informed and believe, and thereon allege, that defendant 22 James Kirk is a resident of the State of California. Defendant has previously filed a 23 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 24 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 25 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 26 Los Angeles Superior Court (“LASC”), case number BC684047. 27 443. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Judie Jean Kirksey is a resident of the State of California. Defendant has previously 39245596.3 -84- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 96 of 181 Page ID #:96 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 444. Plaintiffs are informed and believe and thereon allege that Defendant 6 Nicole Kirshner is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 445. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Matthew Klemmer is a resident of the State of California. Defendant has previously 11 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 12 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 13 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 14 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 15 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 16 of the County of Los Angeles, State of California. 17 446. Plaintiffs are informed and believe and thereon allege that Defendant 18 Rebecca Knepper is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 447. Plaintiffs are informed and believe and thereon allege that Defendant 22 Kash Knudson is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 448. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Jazman Glover Kowalczyk is a resident of the State of California. Defendant has 27 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 28 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 39245596.3 -85- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 97 of 181 Page ID #:97 1 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 2 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 3 BC684047. 4 449. Plaintiffs are informed and believe and thereon allege that Defendant 5 Michael Kretschmar is a resident of the State of California, County of Los Angeles. 6 Defendant has, through counsel, asserted or threatened to assert claims against 7 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 8 450. Plaintiffs are informed and believe, and thereon allege, that defendant 9 Lauren Christine Krueger is a resident of the State of California. Defendant has 10 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 11 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 12 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 13 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 14 BC684047. 15 451. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Madisyn Kuntz is a resident of the State of California. Defendant has previously 17 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 18 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 19 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 20 Los Angeles Superior Court (“LASC”), case number BC684047. 21 452. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Scott T. Kuntz is a resident of the State of California. Defendant has previously filed 23 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 24 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 25 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 26 Los Angeles Superior Court (“LASC”), case number BC684047. 27 453. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Brittany LaJoie is a resident of the State of California. Defendant has previously 39245596.3 -86- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 98 of 181 Page ID #:98 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 454. Plaintiffs are informed and believe and thereon allege that Defendant 6 Michael Landron is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 455. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Brooke Laney is a resident of the State of California. Defendant has previously filed 11 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 12 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 13 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 14 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 15 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 16 of the County of Los Angeles, State of California. 17 456. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Logan LaPorte is a resident of the State of California. Defendant has previously 19 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 20 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 21 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 22 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 23 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 24 of the County of Los Angeles, State of California. 25 457. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Mitchell LaPorte is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -87- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 99 of 181 Page ID #:99 1 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 2 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 3 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 4 of the County of Los Angeles, State of California. 5 458. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Susie LaPorte is a resident of the State of California. Defendant has previously filed 7 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 8 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 9 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 10 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 11 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 12 of the County of Los Angeles, State of California. 13 459. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Richard Larson is a resident of the State of California. Defendant has previously 15 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 16 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 17 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 18 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 19 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 20 of the County of Los Angeles, State of California. 21 460. Plaintiffs are informed and believe and thereon allege that Defendant 22 Chelsea Laurent is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 461. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Jamie Lavery is a resident of the State of California. Defendant has previously filed 27 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 28 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 39245596.3 -88- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 100 of 181 Page ID #:100 1 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 2 Angeles Superior Court (“LASC”), case number BC687120. 3 462. Plaintiffs are informed and believe and thereon allege that Defendant 4 Nicholas Lawlor is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 463. Plaintiffs are informed and believe and thereon allege that Defendant 8 Tiffani Lawyer is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 464. Plaintiffs are informed and believe and thereon allege that Defendant 12 Susan Learn is a resident of the State of California. Defendant has, through counsel, 13 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 14 2017, shooting incident in Las Vegas, Nevada. 15 465. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Cara Ledergerber is a resident of the State of California. Defendant has previously 17 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 18 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 19 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 20 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 21 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 22 of the County of Los Angeles, State of California. 23 466. Plaintiffs are informed and believe and thereon allege that Defendant 24 Ruth Legaspi is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 467. Plaintiffs are informed and believe and thereon allege that Defendant 28 Delane Leivas is a resident of the State of California, County of Ventura. Defendant 39245596.3 -89- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 101 of 181 Page ID #:101 1 has, through counsel, asserted or threatened to assert claims against Plaintiffs based 2 upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 3 468. Plaintiffs are informed and believe and thereon allege that Defendant 4 Delanie Leone is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 469. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Catherine Lester is a resident of the State of California. Defendant has previously 9 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 10 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 11 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 12 Los Angeles Superior Court (“LASC”), case number BC684047. 13 470. Plaintiffs are informed and believe and thereon allege that Defendant 14 Haley Lewis is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 471. Plaintiffs are informed and believe and thereon allege that Defendant 18 Judith Leyn is a resident of the State of California. Defendant has, through counsel, 19 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 20 2017, shooting incident in Las Vegas, Nevada. 21 472. Plaintiffs are informed and believe and thereon allege that Defendant 22 Linda Liewsuwanphong is a resident of the State of California. Defendant has, 23 through counsel, asserted or threatened to assert claims against Plaintiffs based upon 24 the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 473. Plaintiffs are informed and believe and thereon allege that Defendant 26 Pridee J. Liewsuwanphong is a resident of the State of California. Defendant has, 27 through counsel, asserted or threatened to assert claims against Plaintiffs based upon 28 the October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -90- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 102 of 181 Page ID #:102 1 474. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Sophia Lima is a resident of the State of California. Defendant has previously filed a 3 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 6 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 7 number BC687120, 8 475. Plaintiffs are informed and believe and thereon allege that Defendant 9 Michael Ljubic is a resident of the State of California. Defendant has, through 10 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 11 October 1, 2017, shooting incident in Las Vegas, Nevada. 12 476. Plaintiffs are informed and believe and thereon allege that Defendant 13 Michelle Ljubic is a resident of the State of California, County of Los Angeles. 14 Defendant has, through counsel, asserted or threatened to assert claims against 15 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 16 477. Plaintiffs are informed and believe and thereon allege that Defendant 17 Nikolas Ljubic is a resident of the State of California. Defendant has, through 18 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 19 October 1, 2017, shooting incident in Las Vegas, Nevada. 20 478. Plaintiffs are informed and believe, and thereon allege, that defendant 21 Elvia Llamas is a resident of the State of California. Defendant has previously filed 22 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 23 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 24 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 25 Los Angeles Superior Court (“LASC”), case number BC684047. 26 479. Plaintiffs are informed and believe, and thereon allege, that defendant 27 Manuel Llamas is a resident of the State of California. Defendant has previously 28 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 39245596.3 -91- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 103 of 181 Page ID #:103 1 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 2 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 3 Los Angeles Superior Court (“LASC”), case number BC684047. 4 480. Plaintiffs are informed and believe and thereon allege that Defendant 5 Delaney Llanusa is a resident of the State of California. Defendant has, through 6 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 7 October 1, 2017, shooting incident in Las Vegas, Nevada. 8 481. Plaintiffs are informed and believe and thereon allege that Defendant 9 Valarie Loera is a resident of the State of California. Defendant has, through 10 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 11 October 1, 2017, shooting incident in Las Vegas, Nevada. 12 482. Plaintiffs are informed and believe and thereon allege that Defendant 13 Leah Loewenthal is a resident of the State of California, County of Los Angeles. 14 Defendant has, through counsel, asserted or threatened to assert claims against 15 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 16 483. Plaintiffs are informed and believe and thereon allege that Defendant 17 Arla Loncar is a resident of the State of California. Defendant has, through counsel, 18 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 19 2017, shooting incident in Las Vegas, Nevada. 20 484. Plaintiffs are informed and believe and thereon allege that Defendant 21 Blake Loncar is a resident of the State of California. Defendant has, through 22 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 23 October 1, 2017, shooting incident in Las Vegas, Nevada. 24 485. Plaintiffs are informed and believe, and thereon allege, that defendant 25 Alma Lopez is a resident of the State of California. Defendant has previously filed a 26 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 27 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 28 39245596.3 -92- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 104 of 181 Page ID #:104 1 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 486. Plaintiffs are informed and believe and thereon allege that Defendant 4 Kimberly Loring is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 487. Plaintiffs are informed and believe and thereon allege that Defendant 8 Leticia Luna is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 488. Plaintiffs are informed and believe, and thereon allege, that defendant 12 A.M., a minor, is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC687120. 17 489. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Bo Magee is a resident of the State of California. Defendant has previously filed a 19 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 20 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 21 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 22 Los Angeles Superior Court (“LASC”), case number BC684047. 23 490. Plaintiffs are informed and believe and thereon allege that Defendant 24 Kelcy Maio is a resident of the State of California, County of Santa Barbara. 25 Defendant has, through counsel, asserted or threatened to assert claims against 26 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 27 491. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Claudia Majalca is a resident of the State of California. Defendant has previously 39245596.3 -93- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 105 of 181 Page ID #:105 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 492. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Emily Majer is a resident of the State of California. Defendant has previously filed a 7 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 8 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 9 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 10 Los Angeles Superior Court (“LASC”), case number BC684047. 11 493. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Brian Mallette is a resident of the State of California. Defendant has previously filed 13 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 16 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 17 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 18 of the County of Los Angeles, State of California. 19 494. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Jeff Manahan is a resident of the State of California. Defendant has previously filed 21 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 24 Los Angeles Superior Court (“LASC”), case number BC684047. 25 495. Plaintiffs are informed and believe and thereon allege that Defendant 26 Kevin Manahan is a resident of the State of California, County of Los Angeles. 27 Defendant has, through counsel, asserted or threatened to assert claims against 28 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -94- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 106 of 181 Page ID #:106 1 496. Plaintiffs are informed and believe and thereon allege that Defendant 2 Ashley Mansperger is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 497. Plaintiffs are informed and believe and thereon allege that Defendant 6 Thomas Martin is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 498. Plaintiffs are informed and believe and thereon allege that Defendant 10 Andrew Martinez is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 499. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Elisa Martinez is a resident of the State of California. Defendant has previously filed 15 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 16 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 17 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 18 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 19 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 20 of the County of Los Angeles, State of California. 21 500. Plaintiffs are informed and believe and thereon allege that Defendant 22 Regina R. Martinez is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 501. Plaintiffs are informed and believe and thereon allege that Defendant 26 Salvador Martinez is a resident of the State of California, County of Los Angeles. 27 Defendant has, through counsel, asserted or threatened to assert claims against 28 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -95- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 107 of 181 Page ID #:107 1 502. Plaintiffs are informed and believe and thereon allege that Defendant 2 Somer Martinez is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 503. Plaintiffs are informed and believe and thereon allege that Defendant 6 Tony Martinez is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 504. Plaintiffs are informed and believe and thereon allege that Defendant 10 William Mason is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 505. Plaintiffs are informed and believe and thereon allege that Defendant 14 Adam Matz is a resident of the State of California. Defendant has, through counsel, 15 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 16 2017, shooting incident in Las Vegas, Nevada. 17 506. Plaintiffs are informed and believe and thereon allege that Defendant 18 Holly Mayes is a resident of the State of California. Defendant has, through counsel, 19 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 20 2017, shooting incident in Las Vegas, Nevada. 21 507. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Charles Mayfield IV is a resident of the State of California. Defendant has 23 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 24 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 25 shooting incident in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 26 15, 2017, in the Los Angeles Superior Court (“LASC”), case number BC687120. 27 508. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Charles Mayfield is a resident of the State of California. Defendant has previously 39245596.3 -96- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 108 of 181 Page ID #:108 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC687120. 5 509. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Christine A. Mayfield is a resident of the State of California. Defendant has 7 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 8 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 9 shooting incident in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 10 15, 2017, in the Los Angeles Superior Court (“LASC”), case number BC687120. 11 510. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Diana De La Maza is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 16 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 17 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 18 of the County of Los Angeles, State of California. 19 511. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Roland De La Maza is a resident of the State of California. Defendant has 21 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 22 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 23 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 24 Mayfield, et al. v. MGM, filed December 15, 2017, in the Los Angeles Superior 25 Court (“LASC”), case number BC687120, Plaintiffs are informed and believe that 26 Defendant is a resident of the County of Los Angeles, State of California. 27 512. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Genevieve Mazza is a resident of the State of California. Defendant has previously 39245596.3 -97- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 109 of 181 Page ID #:109 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 513. Plaintiffs are informed and believe and thereon allege that Defendant 6 Shande McCann is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 514. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Karen McCorkle is a resident of the State of California. Defendant has previously 11 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 12 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 13 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 14 Los Angeles Superior Court (“LASC”), case number BC684047. 15 515. Plaintiffs are informed and believe and thereon allege that Defendant 16 Daniel McDonald is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 516. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Lontisha McGilberry is a resident of the State of California. Defendant has 21 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 22 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 23 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 24 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 25 BC684047. 26 517. Plaintiffs are informed and believe and thereon allege that Defendant 27 Julie McGinis is a resident of the State of California. Defendant has, through 28 39245596.3 -98- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 110 of 181 Page ID #:110 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 518. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Cherish McGuire is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the 8 Los Angeles Superior Court (“LASC”), case number BC687120. 9 519. Plaintiffs are informed and believe and thereon allege that Defendant 10 Stephanie McKiernan is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 520. Plaintiffs are informed and believe and thereon allege that Defendant 14 Cheryl McPherson is a resident of the State of California, County of Los Angeles. 15 Defendant has, through counsel, asserted or threatened to assert claims against 16 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 17 521. Plaintiffs are informed and believe and thereon allege that Defendant 18 Mark McShane is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 522. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Ashley-Dawn L. Mead is a resident of the State of California. Defendant has 23 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 24 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 25 shooting incident in Las Vegas, Nevada, in Gasper, et al. v. MGM, filed November 26 20, 2017, in Los Angeles Superior Court (“LASC”), case number BC684143. 27 523. Plaintiffs are informed and believe and thereon allege that Defendant 28 David Medina is a resident of the State of California. Defendant has, through 39245596.3 -99- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 111 of 181 Page ID #:111 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 524. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Johnathan Daniel Medina is a resident of the State of California. Defendant has 5 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 6 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 7 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 8 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 9 BC684047. 10 525. Plaintiffs are informed and believe, and thereon allege, that defendant 11 Rachelle Melocoton is a resident of the State of California. Defendant has 12 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 13 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 14 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 15 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 16 BC684047. 17 526. Plaintiffs are informed and believe and thereon allege that Defendant 18 Raymond Merkley is a resident of the State of California, County of Los Angeles. 19 Defendant has, through counsel, asserted or threatened to assert claims against 20 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 21 527. Plaintiffs are informed and believe and thereon allege that Defendant 22 Jim Merrifield is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 528. Plaintiffs are informed and believe, and thereon allege that on October 26 1, 2017, decedent Patricia Mestas, was a resident of the State of California. 27 Plaintiffs are informed and believe and thereon allege that Defendants, the Estate of 28 Patricia Mestas and Jeremy Schmidt (surviving son, heir and successor-in-interest) 39245596.3 -100- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 112 of 181 Page ID #:112 1 have, through counsel, made claims against Plaintiffs based upon the October 1, 2 2017, shooting incident in Las Vegas, Nevada, or, alternatively, have indicated an 3 intent to make such claims in the future (such as by way of the filing of a separate 4 lawsuit – now dismissed, by way of a letter of representation of counsel, or by way 5 of an evidence preservation letter from counsel). 6 529. Plaintiffs are informed and believe, and thereon allege, that defendant 7 Derek Miller is a resident of the State of California. Defendant has previously filed a 8 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 9 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 10 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 11 Angeles Superior Court (“LASC”), case number BC687120. 12 530. Plaintiffs are informed and believe and thereon allege that Defendant 13 Kayla Mills is a resident of the State of California. Defendant has, through counsel, 14 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 15 2017, shooting incident in Las Vegas, Nevada. 16 531. Plaintiffs are informed and believe, and thereon allege, that defendant 17 Melissa Mina is a resident of the State of California. Defendant has previously filed 18 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 19 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 20 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 21 Los Angeles Superior Court (“LASC”), case number BC684047. 22 532. Plaintiffs are informed and believe and thereon allege that Defendant 23 Keith Mineo is a resident of the State of California. Defendant has, through counsel, 24 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 25 2017, shooting incident in Las Vegas, Nevada. 26 533. Plaintiffs are informed and believe and thereon allege that Defendant 27 Rosa Miranda is a resident of the State of California. Defendant has, through 28 39245596.3 -101- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 113 of 181 Page ID #:113 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 534. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Alexandria Mitchell is a resident of the State of California. Defendant has 5 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 6 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 7 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 8 Abraham, et al. v. MGM, filed November 20, 2017, in the Los Angeles Superior 9 Court (“LASC”), case number BC684047, Plaintiffs are informed and believe that 10 Defendant is a resident of the County of Los Angeles, State of California. 11 535. Plaintiffs are informed and believe and thereon allege that Defendant 12 Debra Mitchell is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 536. Plaintiffs are informed and believe and thereon allege that Defendant 16 Michelle Montoya is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 537. Plaintiffs are informed and believe and thereon allege that Defendant 20 Dodi Moore is a resident of the State of California, County of Los Angeles. 21 Defendant has, through counsel, asserted or threatened to assert claims against 22 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 23 538. Plaintiffs are informed and believe and thereon allege that Defendant 24 Lisa Moran is a resident of the State of California. Defendant has, through counsel, 25 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 26 2017, shooting incident in Las Vegas, Nevada. 27 539. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Bambi Rene Moreau is a resident of the State of California. Defendant has 39245596.3 -102- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 114 of 181 Page ID #:114 1 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 2 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 3 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 4 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 5 BC684047. 6 540. Plaintiffs are informed and believe, and thereon allege, that defendant 7 Scott Moreau is a resident of the State of California. Defendant has previously filed 8 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 9 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 10 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 11 Los Angeles Superior Court (“LASC”), case number BC684047. 12 541. Plaintiffs are informed and believe, and thereon allege, that defendant 13 Britnie L. Morgan is a resident of the State of California. Defendant has previously 14 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 15 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 16 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 17 Los Angeles Superior Court (“LASC”), case number BC684047. 18 542. Plaintiffs are informed and believe, and thereon allege, that defendant 19 Candice Morgan is a resident of the State of California. Defendant has previously 20 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 21 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 22 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 23 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 24 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 25 of the County of Los Angeles, State of California. 26 543. Plaintiffs are informed and believe and thereon allege that Defendant 27 Roger Mozda is a resident of the State of California. Defendant has, through 28 39245596.3 -103- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 115 of 181 Page ID #:115 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 544. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Jillian Mueller is a resident of the State of California. Defendant has previously filed 5 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 6 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 7 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 8 Los Angeles Superior Court (“LASC”), case number BC684047. 9 545. Plaintiffs are informed and believe and thereon allege that Defendant 10 Jonathan Mulligan is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 546. Plaintiffs are informed and believe and thereon allege that Defendant 14 Lisa Munoz is a resident of the State of California. Defendant has, through counsel, 15 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 16 2017, shooting incident in Las Vegas, Nevada. 17 547. Plaintiffs are informed and believe and thereon allege that Defendant 18 Kevin Murphy is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 548. Plaintiffs are informed and believe and thereon allege that Defendant 22 Chris W. Murray is a resident of the State of California, County of Los Angeles. 23 Defendant has, through counsel, asserted or threatened to assert claims against 24 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 549. Plaintiffs are informed and believe and thereon allege that Defendant 26 Sharmen Murray is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -104- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 116 of 181 Page ID #:116 1 550. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Lisa Muzycka is a resident of the State of California. Defendant has previously filed 3 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 6 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 7 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 8 of the County of Los Angeles, State of California. 9 551. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Joseph M. Napoli is a resident of the State of California. Defendant has previously 11 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 12 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 13 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 14 Los Angeles Superior Court (“LASC”), case number BC684047. 15 552. Plaintiffs are informed and believe and thereon allege that Defendant 16 Marissa Narvaez is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 553. Plaintiffs are informed and believe and thereon allege that Defendant 20 Brittany Negrette is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 554. Plaintiffs are informed and believe and thereon allege that Defendant 24 Joanne Nelson is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 555. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Robert Troy Nelson is a resident of the State of California. Defendant has previously 39245596.3 -105- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 117 of 181 Page ID #:117 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 556. Plaintiffs are informed and believe and thereon allege that Defendant 6 Marisa Newman is a resident of the State of California, County of Los Angeles. 7 Defendant has, through counsel, asserted or threatened to assert claims against 8 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 9 557. Plaintiffs are informed and believe and thereon allege that Defendant 10 Frank Nicassio is a resident of the State of California, County of Los Angeles. 11 Defendant has, through counsel, asserted or threatened to assert claims against 12 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 13 558. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Gregory Nix is a resident of the State of California. Defendant has previously filed a 15 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 16 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 17 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 18 Los Angeles Superior Court (“LASC”), case number BC684047. 19 559. Plaintiffs are informed and believe and thereon allege that Defendant 20 Cherie Noll is a resident of the State of California. Defendant has, through counsel, 21 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 22 2017, shooting incident in Las Vegas, Nevada. 23 560. Plaintiffs are informed and believe and thereon allege that Defendant 24 Jeanette Nugent is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 561. Plaintiffs are informed and believe and thereon allege that Defendant 28 Ana Nunez is a resident of the State of California. Defendant has, through counsel, 39245596.3 -106- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 118 of 181 Page ID #:118 1 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 2 2017, shooting incident in Las Vegas, Nevada. 3 562. Plaintiffs are informed and believe and thereon allege that Defendant 4 Luis Nunez is a resident of the State of California. Defendant has, through counsel, 5 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 6 2017, shooting incident in Las Vegas, Nevada. 7 563. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Elizabeth Okoro is a resident of the State of California. Defendant has previously 9 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 10 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 11 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 12 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 13 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 14 of the County of Los Angeles, State of California. 15 564. Plaintiffs are informed and believe and thereon allege that Defendant 16 Lindsay Okray is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 565. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Brian O'Leary is a resident of the State of California. Defendant has previously filed 21 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 24 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 25 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 26 of the County of Los Angeles, State of California. 27 566. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Carrie O'Leary is a resident of the State of California. Defendant has previously 39245596.3 -107- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 119 of 181 Page ID #:119 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 4 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 5 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 6 of the County of Los Angeles, State of California. 7 567. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Virginia Olen is a resident of the State of California. Defendant has previously filed 9 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 10 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 11 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 12 Los Angeles Superior Court (“LASC”), case number BC684047. 13 568. Plaintiffs are informed and believe and thereon allege that Defendant 14 Renee Oliver is a resident of the State of California. Defendant has, through counsel, 15 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 16 2017, shooting incident in Las Vegas, Nevada. 17 569. Plaintiffs are informed and believe and thereon allege that Defendant 18 Leona Olson is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 570. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Cynthia Olvera is a resident of the State of California. Defendant has previously 23 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 24 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 25 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 26 Los Angeles Superior Court (“LASC”), case number BC684047. 27 571. Plaintiffs are informed and believe and thereon allege that Defendant 28 Ariel Ontman is a resident of the State of California, County of Los Angeles. 39245596.3 -108- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 120 of 181 Page ID #:120 1 Defendant has, through counsel, asserted or threatened to assert claims against 2 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 3 572. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Claudia Oropeza is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 8 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Los Angeles, State of California. 11 573. Plaintiffs are informed and believe and thereon allege that Defendant 12 Michelle Orozco is a resident of the State of California, County of Los Angeles. 13 Defendant has, through counsel, asserted or threatened to assert claims against 14 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 15 574. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Theresa Ortiz is a resident of the State of California. Defendant has previously filed 17 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 18 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 19 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 20 Los Angeles Superior Court (“LASC”), case number BC684047. 21 575. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Tawanya Otto is a resident of the State of California. Defendant has previously filed 23 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 24 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 25 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 26 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 27 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 28 of the County of Los Angeles, State of California. 39245596.3 -109- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 121 of 181 Page ID #:121 1 576. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Destiny Pacheco is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 577. Plaintiffs are informed and believe and thereon allege that Defendant 8 Elijah Pacheco is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 578. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Leslie Lynn Paiz is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 579. Plaintiffs are informed and believe and thereon allege that Defendant 18 Rocky Palermo is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 580. Plaintiffs are informed and believe and thereon allege that Defendant 22 Melanie Palmer is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 581. Plaintiffs are informed and believe and thereon allege that Defendant 26 Sally Palmer is a resident of the State of California. Defendant has, through counsel, 27 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 28 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -110- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 122 of 181 Page ID #:122 1 582. Plaintiffs are informed and believe and thereon allege that Defendant 2 Haley Panno is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 583. Plaintiffs are informed and believe and thereon allege that Defendant 6 Kylie Panno is a resident of the State of California. Defendant has, through counsel, 7 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 8 2017, shooting incident in Las Vegas, Nevada. 9 584. Plaintiffs are informed and believe, and thereon allege that on October 10 1, 2017, decedent Rachael Parker, was a resident of the State of California. 11 Plaintiffs are informed and believe and thereon allege that Defendants, the Estate of 12 Rachael Parker, Collin Parker (surviving father, heir and successor-in-interest), and 13 Robin Monter (surviving mother, heir and successor-in-interest) have, through 14 counsel, made claims against Plaintiffs based upon the October 1, 2017, shooting 15 incident in Las Vegas, Nevada, or, alternatively, have indicated an intent to make 16 such claims in the future (such as by way of the filing of a separate lawsuit – now 17 dismissed, by way of a letter of representation of counsel, or by way of an evidence 18 preservation letter from counsel). 19 585. Plaintiffs are informed and believe and thereon allege that Defendant 20 Reighlynn Parsley is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 586. Plaintiffs are informed and believe and thereon allege that Defendant 24 Jason Parsons is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 587. Plaintiffs are informed and believe and thereon allege that Defendant 28 Davon Patterson is a resident of the State of California. Defendant has, through 39245596.3 -111- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 123 of 181 Page ID #:123 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 588. Plaintiffs are informed and believe and thereon allege that Defendant 4 Michael Patterson II is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 589. Plaintiffs are informed and believe and thereon allege that Defendant 8 Janice Pennington is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 590. Plaintiffs are informed and believe and thereon allege that Defendant 12 Kimberlee Peoples is a resident of the State of California, County of Los Angeles. 13 Defendant has, through counsel, asserted or threatened to assert claims against 14 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 15 591. Plaintiffs are informed and believe and thereon allege that Defendant 16 Elizabeth Perez is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 592. Plaintiffs are informed and believe and thereon allege that Defendant 20 Paul Perez is a resident of the State of California. Defendant has, through counsel, 21 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 22 2017, shooting incident in Las Vegas, Nevada. 23 593. Plaintiffs are informed and believe and thereon allege that Defendant 24 Eric Perkins is a resident of the State of California. Defendant has, through counsel, 25 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 26 2017, shooting incident in Las Vegas, Nevada. 27 594. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Denine Peters is a resident of the State of California. Defendant has previously filed 39245596.3 -112- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 124 of 181 Page ID #:124 1 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 2 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 3 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 595. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Danyale Petterson is a resident of the State of California. Defendant has previously 7 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 8 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 9 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 10 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 11 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 12 of the County of Los Angeles, State of California. 13 596. Plaintiffs are informed and believe, and thereon allege that on October 14 1, 2017, decedent John Phippen, was a resident of the State of California. Plaintiffs 15 are informed and believe and thereon allege that Defendants, the Estate of John 16 Phippen, Amanda Davis (surviving daughter, heir and successor-in interest to 17 decedent), Travis Phippen (surviving son, heir and successor-in interest to 18 decedent), Nathan Phippen (surviving son, heir and successor-in interest to 19 decedent), A.P. (minor and successor in interest to decedent) are residents of the 20 State of California. Defendants have, through counsel, made claims against 21 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada, 22 or, alternatively, have indicated an intent to make such claims in the future (such as 23 by way of the filing of a separate lawsuit – now dismissed, by way of a letter of 24 representation of counsel, or by way of an evidence preservation letter from 25 counsel). The residency of these Defendants in the County of Los Angeles, State of 26 California was represented to a court in a Complaint in dismissed action Mayfield, et 27 al. v. MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), 28 case number BC687120. 39245596.3 -113- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 125 of 181 Page ID #:125 1 597. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Brian Pickens is a resident of the State of California. Defendant has previously filed 3 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 6 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 7 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 8 of the County of Los Angeles, State of California. 9 598. Plaintiffs are informed and believe and thereon allege that Defendant 10 Bersabe Pineda is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 599. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Jack Pinkston is a resident of the State of California. Defendant has previously filed 15 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 16 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 17 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 18 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 19 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 20 of the County of Los Angeles, State of California. 21 600. Plaintiffs are informed and believe and thereon allege that Defendant 22 Leonel M. Plata Jr. is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 601. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Karlee Poe is a resident of the State of California. Defendant has previously filed a 27 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 28 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 39245596.3 -114- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 126 of 181 Page ID #:126 1 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 2 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 3 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 4 of the County of Ventura, State of California. 5 602. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Mylika Pope is a resident of the State of California. Defendant has previously filed a 7 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 8 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 9 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 10 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 11 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 12 of the County of Los Angeles, State of California. 13 603. Plaintiffs are informed and believe and thereon allege that Defendant 14 Brent Poppen is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 604. Plaintiffs are informed and believe and thereon allege that Defendant 18 Keith Powers is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 605. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Jessica Presten is a resident of the State of California. Defendant has previously 23 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 24 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 25 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 26 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 27 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 28 of the County of Los Angeles, State of California. 39245596.3 -115- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 127 of 181 Page ID #:127 1 606. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Shawn Price is a resident of the State of California. Defendant has previously filed a 3 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 6 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 7 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 8 of the County of Los Angeles, State of California. 9 607. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Denise Provencio is a resident of the State of California. Defendant has previously 11 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 12 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 13 in Las Vegas, Nevada, in Provencio v. MGM, filed November 15, 2017, in Clark 14 County District Court (“Clark County”), case number A-17-764708. 15 608. Plaintiffs are informed and believe and thereon allege that Defendant 16 Kendall Quiroz is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 609. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Magee R.Segal is a resident of the State of California. Defendant has previously 21 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 22 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 23 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 24 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 25 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 26 of the County of Los Angeles, State of California. 27 610. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Dominic Rabanal is a resident of the State of California. Defendant has previously 39245596.3 -116- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 128 of 181 Page ID #:128 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC687120. 5 611. Plaintiffs are informed and believe and thereon allege that Defendant 6 Diego Armando Ramirez is a resident of the State of California, County of Ventura. 7 Defendant has, through counsel, asserted or threatened to assert claims against 8 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 9 612. Plaintiffs are informed and believe and thereon allege that Defendant 10 Frances Ramirez is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 613. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Krystal Ramirez is a resident of the State of California. Defendant has previously 15 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 16 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 17 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 18 Los Angeles Superior Court (“LASC”), case number BC684047. 19 614. Plaintiffs are informed and believe and thereon allege that Defendant 20 Renee Ramirez is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 615. Plaintiffs are informed and believe and thereon allege that Defendant 24 Sara Ramirez is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 616. Plaintiffs are informed and believe and thereon allege that Defendant 28 Erica Ramos is a resident of the State of California. Defendant has, through 39245596.3 -117- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 129 of 181 Page ID #:129 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 617. Plaintiffs are informed and believe and thereon allege that Defendant 4 Carissa Rash is a resident of the State of California. Defendant has, through counsel, 5 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 6 2017, shooting incident in Las Vegas, Nevada. 7 618. Plaintiffs are informed and believe and thereon allege that Defendant 8 Cody Rash is a resident of the State of California. Defendant has, through counsel, 9 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 10 2017, shooting incident in Las Vegas, Nevada. 11 619. Plaintiffs are informed and believe, and thereon allege, that defendant 12 David Rasmusson is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 620. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Michelle Rasmusson is a resident of the State of California. Defendant has 19 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 20 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 21 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 22 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 23 BC684047. 24 621. Plaintiffs are informed and believe, and thereon allege, that defendant 25 Jacob Ratliff is a resident of the State of California. Defendant has previously filed a 26 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 27 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 28 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 39245596.3 -118- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 130 of 181 Page ID #:130 1 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 2 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 3 of the County of Los Angeles, State of California. 4 622. Plaintiffs are informed and believe and thereon allege that Defendant 5 Jacob Ratliff is a resident of the State of California, County of Los Angeles. 6 Defendant has, through counsel, asserted or threatened to assert claims against 7 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 8 623. Plaintiffs are informed and believe and thereon allege that Defendant 9 Glenda Rebollar is a resident of the State of California, County of Los Angeles. 10 Defendant has, through counsel, asserted or threatened to assert claims against 11 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 12 624. Plaintiffs are informed and believe, and thereon allege, that defendant 13 Matthew C. Reed is a resident of the State of California. Defendant has previously 14 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 15 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 16 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 17 Los Angeles Superior Court (“LASC”), case number BC684047. 18 625. Plaintiffs are informed and believe and thereon allege that Defendant 19 Tricia Sean Reed is a resident of the State of California. Defendant has, through 20 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 21 October 1, 2017, shooting incident in Las Vegas, Nevada. 22 626. Plaintiffs are informed and believe and thereon allege that Defendant 23 Lynne Reick is a resident of the State of California. Defendant has, through counsel, 24 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 25 2017, shooting incident in Las Vegas, Nevada. 26 627. Plaintiffs are informed and believe and thereon allege that Defendant 27 Brody Renaud is a resident of the State of California. Defendant has, through 28 39245596.3 -119- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 131 of 181 Page ID #:131 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 628. Plaintiffs are informed and believe and thereon allege that Defendant 4 Amber Rench is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 629. Plaintiffs are informed and believe and thereon allege that Defendant 8 Jasara Requejo is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 630. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Francisco Resendiz is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 631. Plaintiffs are informed and believe and thereon allege that Defendant 18 Brenda Resnick is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 632. Plaintiffs are informed and believe and thereon allege that Defendant 22 Kristina Reyes is a resident of the State of California, County of Ventura. 23 Defendant has, through counsel, asserted or threatened to assert claims against 24 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 633. Plaintiffs are informed and believe and thereon allege that Defendant 26 Ralph Reyes is a resident of the State of California. Defendant has, through counsel, 27 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 28 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -120- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 132 of 181 Page ID #:132 1 634. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Tara Reyes is a resident of the State of California. Defendant has previously filed a 3 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 6 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 7 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 8 of the County of Los Angeles, State of California. 9 635. Plaintiffs are informed and believe and thereon allege that Defendant 10 Marion Reynolds is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 636. Plaintiffs are informed and believe and thereon allege that Defendant 14 William Reynolds is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 637. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Steven Ribovich is a resident of the State of California. Defendant has previously 19 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 20 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 21 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 22 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 23 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 24 of the County of Ventura, State of California. 25 638. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Marie Rice is a resident of the State of California. Defendant has previously filed a 27 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 28 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 39245596.3 -121- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 133 of 181 Page ID #:133 1 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 639. Plaintiffs are informed and believe and thereon allege that Defendant 4 Gina Richard is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 640. Plaintiffs are informed and believe and thereon allege that Defendant 8 Mindy Ritter is a resident of the State of California. Defendant has, through counsel, 9 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 10 2017, shooting incident in Las Vegas, Nevada. 11 641. Plaintiffs are informed and believe and thereon allege that Defendant 12 Heather Rivera is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 642. Plaintiffs are informed and believe and thereon allege that Defendant 16 Raymond A. Rivera is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 643. Plaintiffs are informed and believe and thereon allege that Defendant 20 Jade Rixey is a resident of the State of California. Defendant has, through counsel, 21 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 22 2017, shooting incident in Las Vegas, Nevada. 23 644. Plaintiffs are informed and believe and thereon allege that Defendant 24 Kurt Roberts is a resident of the State of California. Defendant has, through counsel, 25 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 26 2017, shooting incident in Las Vegas, Nevada. 27 645. Plaintiffs are informed and believe and thereon allege that Defendant 28 Michael Robertson is a resident of the State of California, County of Los Angeles. 39245596.3 -122- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 134 of 181 Page ID #:134 1 Defendant has, through counsel, asserted or threatened to assert claims against 2 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 3 646. Plaintiffs are informed and believe and thereon allege that Defendant 4 Timothy Robinson is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 647. Plaintiffs are informed and believe and thereon allege that Defendant 8 Bernadette Rocha is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 648. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Jennifer Rockwell is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 16 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 17 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 18 of the County of Los Angeles, State of California. 19 649. Plaintiffs are informed and believe and thereon allege that Defendant 20 Saul Rodriguez is a resident of the State of California, County of Los Angeles. 21 Defendant has, through counsel, asserted or threatened to assert claims against 22 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 23 650. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Michael Rogozik is a resident of the State of California. Defendant has previously 25 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 26 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 27 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 28 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 39245596.3 -123- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 135 of 181 Page ID #:135 1 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 2 of the County of Los Angeles, State of California. 3 651. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Monica Rogozik is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 8 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Los Angeles, State of California. 11 652. Plaintiffs are informed and believe and thereon allege that Defendant 12 Marcelina Rojas is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 653. Plaintiffs are informed and believe and thereon allege that Defendant 16 Claudia Romero is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 654. Plaintiffs are informed and believe and thereon allege that Defendant 20 Harry Romero is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 655. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Susan Rose is a resident of the State of California. Defendant has previously filed a 25 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 26 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 27 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 28 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 39245596.3 -124- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 136 of 181 Page ID #:136 1 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 2 of the County of Los Angeles, State of California. 3 656. Plaintiffs are informed and believe and thereon allege that Defendant 4 Anna Ross is a resident of the State of California. Defendant has, through counsel, 5 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 6 2017, shooting incident in Las Vegas, Nevada. 7 657. Plaintiffs are informed and believe, and thereon allege that on October 8 1, 2017, decedent Christopher Roybal, was a resident of the State of California. 9 Plaintiffs are informed and believe and thereon allege that Defendants, the Estate of 10 Christopher Roybal, and Dixie Roybal (surviving spouse, heir and success-in11 interest to decedent) have, through counsel, made claims against Plaintiffs based 12 upon the October 1, 2017, shooting incident in Las Vegas, Nevada, or, alternatively, 13 have indicated an intent to make such claims in the future (such as by way of the 14 filing of a separate lawsuit – now dismissed, by way of a letter of representation of 15 counsel, or by way of an evidence preservation letter from counsel). The Defendants 16 are residents of the County of Riverside, State of California, and the residency of 17 these Defendants was identified to a court in a Complaint in the dismissed action 18 Roybal v. MGM, filed November 20, 2017, in the Los Angeles Superior Court 19 (“LASC”), case number BC684046. 20 658. Plaintiffs are informed and believe, and thereon allege, that defendant 21 Chantel Rubio is a resident of the State of California. Defendant has previously filed 22 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 23 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 24 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 25 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 26 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 27 of the County of Los Angeles, State of California. 28 39245596.3 -125- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 137 of 181 Page ID #:137 1 659. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Lisa Rudberg is a resident of the State of California. Defendant has previously filed 3 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 660. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Lucia Rudela is a resident of the State of California. Defendant has previously filed 9 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 10 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 11 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 12 Los Angeles Superior Court (“LASC”), case number BC684047. 13 661. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Laura Ruiz is a resident of the State of California. Defendant has previously filed a 15 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 16 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 17 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 18 Los Angeles Superior Court (“LASC”), case number BC684047. 19 662. Plaintiffs are informed and believe and thereon allege that Defendant 20 Amanda Rumble is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 663. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Joanne Rusconi is a resident of the State of California. Defendant has previously 25 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 26 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 27 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 28 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 39245596.3 -126- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 138 of 181 Page ID #:138 1 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 2 of the County of Los Angeles, State of California. 3 664. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Michael Coty Rye is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 8 Los Angeles Superior Court (“LASC”), case number BC684047. 9 665. Plaintiffs are informed and believe and thereon allege that Defendant 10 Eric Rymer is a resident of the State of California. Defendant has, through counsel, 11 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 12 2017, shooting incident in Las Vegas, Nevada. 13 666. Plaintiffs are informed and believe and thereon allege that Defendant 14 Roni Rymer is a resident of the State of California. Defendant has, through counsel, 15 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 16 2017, shooting incident in Las Vegas, Nevada. 17 667. Plaintiffs are informed and believe, and thereon allege, that defendant 18 H.S., a minor, is a resident of the State of California. Defendant has previously filed 19 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 20 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 21 Las Vegas, Nevada, in Staples, et al. v. MGM, filed November 20, 2017, in Los 22 Angeles Superior Court (“LASC”), case number BC684142. 23 668. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Allison Saelee is a resident of the State of California. Defendant has previously filed 25 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 26 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 27 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 28 Los Angeles Superior Court (“LASC”), case number BC684047. 39245596.3 -127- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 139 of 181 Page ID #:139 1 669. Plaintiffs are informed and believe and thereon allege that Defendant 2 Justine Salas is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 670. Plaintiffs are informed and believe and thereon allege that Defendant 6 Victoria Salas is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 671. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Crystal Salazar is a resident of the State of California. Defendant has previously 11 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 12 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 13 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 14 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 15 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 16 of the County of Ventura, State of California. 17 672. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Renee Salazar is a resident of the State of California. Defendant has previously filed 19 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 20 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 21 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 22 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 23 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 24 of the County of Los Angeles, State of California. 25 673. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Selso Salazar is a resident of the State of California. Defendant has previously filed 27 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 28 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 39245596.3 -128- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 140 of 181 Page ID #:140 1 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 2 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 3 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 4 of the County of Los Angeles, State of California. 5 674. Plaintiffs are informed and believe and thereon allege that Defendant 6 Amanda Salmon is a resident of the State of California, County of Los Angeles. 7 Defendant has, through counsel, asserted or threatened to assert claims against 8 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 9 675. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Amanda Sambrano is a resident of the State of California. Defendant has previously 11 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 12 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 13 in Las Vegas, Nevada, in Spencer, et al. v. Paddock, filed October 17, 2017, in Los 14 Angeles Superior Court (“LASC”), case number BC680065. 15 676. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Janae Sambrano is a resident of the State of California. Defendant has previously 17 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 18 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 19 in Las Vegas, Nevada, in Spencer, et al. v. Paddock, filed October 17, 2017, in Los 20 Angeles Superior Court (“LASC”), case number BC680065. 21 677. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Jeffery Sambrano is a resident of the State of California. Defendant has previously 23 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 24 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 25 in Las Vegas, Nevada, in Spencer, et al. v. Paddock, filed October 17, 2017, in Los 26 Angeles Superior Court (“LASC”), case number BC680065. 27 678. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Stephen Sambrano is a resident of the State of California. Defendant has previously 39245596.3 -129- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 141 of 181 Page ID #:141 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Spencer, et al. v. Paddock, filed October 17, 2017, in Los 4 Angeles Superior Court (“LASC”), case number BC680065. 5 679. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Ethan Sanchez is a resident of the State of California. Defendant has previously filed 7 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 8 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 9 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 10 Angeles Superior Court (“LASC”), case number BC687120. 11 680. Plaintiffs are informed and believe, and thereon allege, that defendant 12 George Sanchez is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 681. Plaintiffs are informed and believe and thereon allege that Defendant 18 Marie Sanchez is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 682. Plaintiffs are informed and believe and thereon allege that Defendant 22 Savannah Sanchez is a resident of the State of California, County of Ventura. 23 Defendant has, through counsel, asserted or threatened to assert claims against 24 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 683. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Trevor Sanders is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -130- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 142 of 181 Page ID #:142 1 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 684. Plaintiffs are informed and believe and thereon allege that Defendant 4 Ernestine Sandoval is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 685. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Calia Sanford is a resident of the State of California. Defendant has previously filed 9 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 10 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 11 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 12 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 13 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 14 of the County of Los Angeles, State of California. 15 686. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Ina Sarkissian is a resident of the State of California. Defendant has previously filed 17 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 18 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 19 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 20 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 21 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 22 of the County of Los Angeles, State of California. 23 687. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Nela Sarkissian is a resident of the State of California. Defendant has previously 25 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 26 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 27 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 28 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 39245596.3 -131- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 143 of 181 Page ID #:143 1 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 2 of the County of Los Angeles, State of California. 3 688. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Casey Scandlyn is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 8 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Los Angeles, State of California. 11 689. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Ilene Scandlyn is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 16 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 17 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 18 of the County of Los Angeles, State of California. 19 690. Plaintiffs are informed and believe, and thereon allege, that defendant 20 David Scantlin is a resident of the State of California. Defendant has previously 21 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 22 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 23 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 24 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 25 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 26 of the County of Los Angeles, State of California. 27 691. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Michelle Scantlin is a resident of the State of California. Defendant has previously 39245596.3 -132- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 144 of 181 Page ID #:144 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 4 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 5 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 6 of the County of Los Angeles, State of California. 7 692. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Ryan L. Scantlin is a resident of the State of California. Defendant has previously 9 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 10 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 11 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 12 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 13 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 14 of the County of Los Angeles, State of California. 15 693. Plaintiffs are informed and believe and thereon allege that Defendant 16 David Scharmack is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 694. Plaintiffs are informed and believe and thereon allege that Defendant 20 Irene Scharmack is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 695. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Rebekah Scheussler is a resident of the State of California. Defendant has 25 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 26 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 27 shooting incident in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 28 15, 2017, in the Los Angeles Superior Court (“LASC”), case number BC687120. 39245596.3 -133- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 145 of 181 Page ID #:145 1 696. Plaintiffs are informed and believe and thereon allege that Defendant 2 Alice Schmidt is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 697. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Lisa Schneider is a resident of the State of California. Defendant has previously 7 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 8 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 9 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 10 Los Angeles Superior Court (“LASC”), case number BC684047. 11 698. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Mark Schneider is a resident of the State of California. Defendant has previously 13 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 14 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 15 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 699. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Michelle Schoneman is a resident of the State of California. Defendant has 19 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 20 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 21 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 22 Abraham, et al. v. MGM, filed November 20, 2017, in the Los Angeles Superior 23 Court (“LASC”), case number BC684047, Plaintiffs are informed and believe that 24 Defendant is a resident of the County of Ventura, State of California. 25 700. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Robert Schrode is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -134- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 146 of 181 Page ID #:146 1 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 2 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 3 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 4 of the County of Los Angeles, State of California. 5 701. Plaintiffs are informed and believe and thereon allege that Defendant 6 Jonathan Schussler is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 702. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Michael Scott is a resident of the State of California. Defendant has previously filed 11 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 12 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 13 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 14 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 15 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 16 of the County of Los Angeles, State of California. 17 703. Plaintiffs are informed and believe and thereon allege that Defendant 18 Janet Seeger is a resident of the State of California. Defendant has, through counsel, 19 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 20 2017, shooting incident in Las Vegas, Nevada. 21 704. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Alicia Segovia is a resident of the State of California. Defendant has previously filed 23 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 24 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 25 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 26 Angeles Superior Court (“LASC”), case number BC687120. 27 705. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Gilbert Segovia is a resident of the State of California. Defendant has previously 39245596.3 -135- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 147 of 181 Page ID #:147 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC687120. 5 706. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Cheryl Seguin is a resident of the State of California. Defendant has previously filed 7 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 8 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 9 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 10 Los Angeles Superior Court (“LASC”), case number BC684047. 11 707. Plaintiffs are informed and believe and thereon allege that Defendant 12 Fred Seguin is a resident of the State of California. Defendant has, through counsel, 13 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 14 2017, shooting incident in Las Vegas, Nevada. 15 708. Plaintiffs are informed and believe and thereon allege that Defendant 16 Tommie Serrano is a resident of the State of California, County of Ventura. 17 Defendant has, through counsel, asserted or threatened to assert claims against 18 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 19 709. Plaintiffs are informed and believe, and thereon allege, that defendant 20 David Sheriff is a resident of the State of California. Defendant has previously filed 21 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 24 Los Angeles Superior Court (“LASC”), case number BC684047. 25 710. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Remo Sheth is a resident of the State of California. Defendant has previously filed a 27 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 28 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 39245596.3 -136- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 148 of 181 Page ID #:148 1 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 2 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 3 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 4 of the County of Los Angeles, State of California. 5 711. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Michael K. Sholan is a resident of the State of California. Defendant has previously 7 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 8 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 9 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 10 Los Angeles Superior Court (“LASC”), case number BC684047. 11 712. Plaintiffs are informed and believe and thereon allege that Defendant 12 Anthony Silva is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 713. Plaintiffs are informed and believe and thereon allege that Defendant 16 Elaine Silvestre is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 714. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Cheyenne Nicole Simon is a resident of the State of California. Defendant has 21 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 22 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 23 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 24 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 25 BC684047. 26 715. Plaintiffs are informed and believe and thereon allege that Defendant 27 Haley Sisneros is a resident of the State of California. Defendant has, through 28 39245596.3 -137- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 149 of 181 Page ID #:149 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 716. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Buddy Skidmore is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 8 Los Angeles Superior Court (“LASC”), case number BC684047. 9 717. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Lee Skolnick is a resident of the State of California. Defendant has previously filed 11 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 12 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 13 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 14 Angeles Superior Court (“LASC”), case number BC687120. 15 718. Plaintiffs are informed and believe and thereon allege that Defendant 16 Shelby Slifka is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 719. Plaintiffs are informed and believe and thereon allege that Defendant 20 Jonathan Sloniger is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 720. Plaintiffs are informed and believe and thereon allege that Defendant 24 Stephanie Smarker is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 721. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Karen Elaine Smerber is a resident of the State of California. Defendant has 39245596.3 -138- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 150 of 181 Page ID #:150 1 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 2 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 3 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 4 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 5 BC684047. 6 722. Plaintiffs are informed and believe, and thereon allege, that defendant 7 Ryan Smith is a resident of the State of California. Defendant has previously filed a 8 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 9 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 10 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 11 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 12 number BC684047. 13 723. Plaintiffs are informed and believe and thereon allege that Defendant 14 Amber Smith is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 724. Plaintiffs are informed and believe and thereon allege that Defendant 18 Dana L. Smith is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 725. Plaintiffs are informed and believe and thereon allege that Defendant 22 Ryan Oneil Smith is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 726. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Danielle Smudde is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -139- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 151 of 181 Page ID #:151 1 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 727. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Misty Snitzer is a resident of the State of California. Defendant has previously filed 5 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 6 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 7 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 8 Angeles Superior Court (“LASC”), case number BC687120. 9 728. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Stephanie Sotomayor is a resident of the State of California. Defendant has 11 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 12 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 13 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 14 Abraham, et al. v. MGM, filed November 20, 2017, in the Los Angeles Superior 15 Court (“LASC”), case number BC684047, Plaintiffs are informed and believe that 16 Defendant is a resident of the County of Los Angeles, State of California. 17 729. Plaintiffs are informed and believe and thereon allege that Defendant 18 Katey Souza is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 730. Plaintiffs are informed and believe and thereon allege that Defendant 22 Cheryl Spencer is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 731. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Keoscha E. Spencer is a resident of the State of California. Defendant has 27 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 28 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 39245596.3 -140- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 152 of 181 Page ID #:152 1 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 2 Abraham, et al. v. MGM, filed November 20, 2017, in the Los Angeles Superior 3 Court (“LASC”), case number BC684047, Plaintiffs are informed and believe that 4 Defendant is a resident of the County of Los Angeles, State of California. 5 732. Plaintiffs are informed and believe, and thereon allege, that defendant 6 Kortney Spencer is a resident of the State of California. Defendant has previously 7 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 8 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 9 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 10 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 11 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 12 of the County of Los Angeles, State of California. 13 733. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Michelle E. Spencer is a resident of the State of California. Defendant has 15 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 16 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 17 shooting incident in Las Vegas, Nevada, in Spencer, et al. v. Paddock, filed October 18 17, 2017, in Los Angeles Superior Court (“LASC”), case number BC680065. 19 734. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Savannah Spencer is a resident of the State of California. Defendant has previously 21 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 22 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 23 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 24 Los Angeles Superior Court (“LASC”), case number BC684047. 25 735. Plaintiffs are informed and believe and thereon allege that Defendant 26 Stephanie Spencer is a resident of the State of California, County of Ventura. 27 Defendant has, through counsel, asserted or threatened to assert claims against 28 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -141- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 153 of 181 Page ID #:153 1 736. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Suzanne Spencer is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 737. Plaintiffs are informed and believe, and thereon allege, that defendant 8 David Spring is a resident of the State of California. Defendant has previously filed 9 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 10 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 11 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 12 Los Angeles Superior Court (“LASC”), case number BC684047. 13 738. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Shannon Springer is a resident of the State of California. Defendant has previously 15 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 16 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 17 in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the 18 Los Angeles Superior Court (“LASC”), case number BC687120. 19 739. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Troy Springer is a resident of the State of California. Defendant has previously filed 21 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the Los 24 Angeles Superior Court (“LASC”), case number BC687120. 25 740. Plaintiffs are informed and believe and thereon allege that Defendant 26 Robert Staggs is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -142- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 154 of 181 Page ID #:154 1 741. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Daniel Staples is a resident of the State of California. Defendant has previously filed 3 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada, in Staples, et al. v. MGM, filed November 20, 2017, in Los 6 Angeles Superior Court (“LASC”), case number BC684142. 7 742. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Samuel Staples is a resident of the State of California. Defendant has previously 9 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 10 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 11 in Las Vegas, Nevada, in Staples, et al. v. MGM, filed November 20, 2017, in Los 12 Angeles Superior Court (“LASC”), case number BC684142. 13 743. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Kristina Staples, an incapacitated person, is a resident of the State of California. 15 Defendant has previously filed a lawsuit (which was subsequently voluntarily 16 dismissed) against one or more of the Plaintiffs, asserting claims arising from the 17 October 1, 2017, shooting incident in Las Vegas, Nevada, in Staples, et al. v. MGM, 18 filed November 20, 2017, in Los Angeles Superior Court (“LASC”), case number 19 BC684142. 20 744. Plaintiffs are informed and believe and thereon allege that Defendant 21 David Statter is a resident of the State of California. Defendant has, through 22 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 23 October 1, 2017, shooting incident in Las Vegas, Nevada. 24 745. Plaintiffs are informed and believe and thereon allege that Defendant 25 Veronica Statter is a resident of the State of California. Defendant has, through 26 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 27 October 1, 2017, shooting incident in Las Vegas, Nevada. 28 39245596.3 -143- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 155 of 181 Page ID #:155 1 746. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Jeffrey Steffens is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 6 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 7 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 8 of the County of Los Angeles, State of California. 9 747. Plaintiffs are informed and believe and thereon allege that Defendant 10 Katie Stern is a resident of the State of California. Defendant has, through counsel, 11 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 12 2017, shooting incident in Las Vegas, Nevada. 13 748. Plaintiffs are informed and believe and thereon allege that Defendant 14 Parker Stevens is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 749. Plaintiffs are informed and believe and thereon allege that Defendant 18 Steve Stewart is a resident of the State of California, County of Los Angeles. 19 Defendant has, through counsel, asserted or threatened to assert claims against 20 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 21 750. Plaintiffs are informed and believe and thereon allege that Defendant 22 Tamara J. Stewart is a resident of the State of California. Defendant has, through 23 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 24 October 1, 2017, shooting incident in Las Vegas, Nevada. 25 751. Plaintiffs are informed and believe and thereon allege that Defendant 26 Michaela Stilwell is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -144- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 156 of 181 Page ID #:156 1 752. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Dana Stout-Wilson is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC684047. 7 753. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Lindsay Stragier is a resident of the State of California. Defendant has previously 9 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 10 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 11 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 12 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 13 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 14 of the County of Los Angeles, State of California. 15 754. Plaintiffs are informed and believe and thereon allege that Defendant 16 Joshua K. Stratton is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 755. Plaintiffs are informed and believe and thereon allege that Defendant 20 Amber Streid is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 756. Plaintiffs are informed and believe and thereon allege that Defendant 24 Shandi Strong is a resident of the State of California, County of Los Angeles. 25 Defendant has, through counsel, asserted or threatened to assert claims against 26 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 27 757. Plaintiffs are informed and believe and thereon allege that Defendant 28 Michelle Stuebe is a resident of the State of California. Defendant has, through 39245596.3 -145- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 157 of 181 Page ID #:157 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 758. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Susanna Suard is a resident of the State of California. Defendant has previously filed 5 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 6 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 7 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 8 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Los Angeles, State of California. 11 759. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Clint Sundeen is a resident of the State of California. Defendant has previously filed 13 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 16 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 17 number BC684047. 18 760. Plaintiffs are informed and believe, and thereon allege, that defendant 19 Kellie Sundeen is a resident of the State of California. Defendant has previously 20 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 21 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 22 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 23 Los Angeles Superior Court (“LASC”), case number BC684047. 24 761. Plaintiffs are informed and believe, and thereon allege, that defendant 25 Kyle C. Sundeen is a resident of the State of California. Defendant has previously 26 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 27 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 28 39245596.3 -146- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 158 of 181 Page ID #:158 1 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 762. Plaintiffs are informed and believe and thereon allege that Defendant 4 Brandi Swan is a resident of the State of California. Defendant has, through counsel, 5 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 6 2017, shooting incident in Las Vegas, Nevada. 7 763. Plaintiffs are informed and believe and thereon allege that Defendant 8 Nicholas Swartz is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 764. Plaintiffs are informed and believe and thereon allege that Defendant 12 Yvette Swartz is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 765. Plaintiffs are informed and believe and thereon allege that Defendant 16 Lynnsey Sweet is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 766. Plaintiffs are informed and believe, and thereon allege, that defendant 20 B.T., a minor, is a resident of the State of California. Defendant has previously filed 21 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 24 Los Angeles Superior Court (“LASC”), case number BC684047. 25 767. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Erin Taber is a resident of the State of California. Defendant has previously filed a 27 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 28 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 39245596.3 -147- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 159 of 181 Page ID #:159 1 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 768. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Ruben Talamantez is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 8 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 9 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 10 of the County of Los Angeles, State of California. 11 769. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Marie Tautrim is a resident of the State of California. Defendant has previously filed 13 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 16 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 17 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 18 of the County of Los Angeles, State of California. 19 770. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Michael Tautrim is a resident of the State of California. Defendant has previously 21 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 22 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 23 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 24 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 25 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 26 of the County of Los Angeles, State of California. 27 771. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Brianna Taylor is a resident of the State of California. Defendant has previously 39245596.3 -148- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 160 of 181 Page ID #:160 1 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 2 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 3 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 772. Plaintiffs are informed and believe and thereon allege that Defendant 6 Jason Taylor is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 773. Plaintiffs are informed and believe, and thereon allege, that defendant 10 John Taylor is a resident of the State of California. Defendant has previously filed a 11 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 12 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 13 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 14 Los Angeles Superior Court (“LASC”), case number BC684047. 15 774. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Tiffany Taylor is a resident of the State of California. Defendant has previously filed 17 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 18 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 19 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 20 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 21 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 22 of the County of Los Angeles, State of California. 23 775. Plaintiffs are informed and believe, and thereon allege that on October 24 1, 2017, decedent Derrick D. Taylor, was a resident of the State of California. 25 Plaintiffs are informed and believe and thereon allege that Defendant, the Estate of 26 Derrick D. Taylor has, through counsel, made claims against Plaintiffs based upon 27 the October 1, 2017, shooting incident in Las Vegas, Nevada, or, alternatively, has 28 indicated an intent to make such claims in the future (such as by way of the filing of 39245596.3 -149- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 161 of 181 Page ID #:161 1 a separate lawsuit – now dismissed, by way of a letter of representation of counsel, 2 or by way of an evidence preservation letter from counsel). 3 776. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Desiree Temple is a resident of the State of California. Defendant has previously 5 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 6 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 7 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 8 Los Angeles Superior Court (“LASC”), case number BC684047. 9 777. Plaintiffs are informed and believe and thereon allege that Defendant 10 Rocky Tepesano is a resident of the State of California, County of Ventura. 11 Defendant has, through counsel, asserted or threatened to assert claims against 12 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 13 778. Plaintiffs are informed and believe and thereon allege that Defendant 14 Janelle Terkeurst is a resident of the State of California. Defendant has, through 15 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 16 October 1, 2017, shooting incident in Las Vegas, Nevada. 17 779. Plaintiffs are informed and believe and thereon allege that Defendant 18 Deborah Thomas is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 780. Plaintiffs are informed and believe and thereon allege that Defendant 22 Jeffrey Thomas is a resident of the State of California, County of Los Angeles. 23 Defendant has, through counsel, asserted or threatened to assert claims against 24 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 781. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Evan Tillema is a resident of the State of California. Defendant has previously filed 27 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 28 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 39245596.3 -150- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 162 of 181 Page ID #:162 1 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 2 Los Angeles Superior Court (“LASC”), case number BC684047. 3 782. Plaintiffs are informed and believe and thereon allege that Defendant 4 Lindsay Tillema is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 783. Plaintiffs are informed and believe and thereon allege that Defendant 8 Jennifer Tillman is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 784. Plaintiffs are informed and believe, and thereon allege, that defendant 12 Joshua Tinoco is a resident of the State of California. Defendant has previously filed 13 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 14 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 15 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 16 Los Angeles Superior Court (“LASC”), case number BC684047. 17 785. Plaintiffs are informed and believe, and thereon allege, that defendant 18 Lanna Tinoco is a resident of the State of California. Defendant has previously filed 19 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 20 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 21 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 22 Los Angeles Superior Court (“LASC”), case number BC684047. 23 786. Plaintiffs are informed and believe and thereon allege that Defendant 24 Sarah Tiscareno is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 787. Plaintiffs are informed and believe and thereon allege that Defendant 28 Alfredo Toledo is a resident of the State of California. Defendant has, through 39245596.3 -151- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 163 of 181 Page ID #:163 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 788. Plaintiffs are informed and believe and thereon allege that Defendant 4 Kenneth Tonkovich is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 789. Plaintiffs are informed and believe and thereon allege that Defendant 8 Johnny Toscano is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 790. Plaintiffs are informed and believe and thereon allege that Defendant 12 Rhonda Trask is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 791. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Robert Trematerra is a resident of the State of California. Defendant has previously 17 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 18 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 19 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 20 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 21 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 22 of the County of Ventura, State of California. 23 792. Plaintiffs are informed and believe and thereon allege that Defendant 24 Hamida Trujillo is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 793. Plaintiffs are informed and believe and thereon allege that Defendant 28 Jacquelyn Trujillo is a resident of the State of California, County of Los Angeles. 39245596.3 -152- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 164 of 181 Page ID #:164 1 Defendant has, through counsel, asserted or threatened to assert claims against 2 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 3 794. Plaintiffs are informed and believe and thereon allege that Defendant 4 Ligia Uriarte is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 795. Plaintiffs are informed and believe and thereon allege that Defendant 8 Alejandra Uribe is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 796. Plaintiffs are informed and believe and thereon allege that Defendant 12 Ricardo Uribe is a resident of the State of California. Defendant has, through 13 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 14 October 1, 2017, shooting incident in Las Vegas, Nevada. 15 797. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Lisa Valdes is a resident of the State of California. Defendant has previously filed a 17 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 18 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 19 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 20 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 21 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 22 of the County of Ventura, State of California. 23 798. Plaintiffs are informed and believe and thereon allege that Defendant 24 Erin Valenzuela is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 799. Plaintiffs are informed and believe and thereon allege that Defendant 28 Jennifer Van Vlymen is a resident of the State of California. Defendant has, through 39245596.3 -153- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 165 of 181 Page ID #:165 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 800. Plaintiffs are informed and believe, and thereon allege, that defendant 4 Nathalie Vanderstay is a resident of the State of California. Defendant has 5 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 6 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 7 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 8 Vanderstay, et al. v. MGM, filed November 13, 2017, in the Los Angeles Superior 9 Court (“LASC”), case number BC683403, Plaintiffs are informed and believe that 10 Defendant is a resident of the County of Los Angeles, State of California. 11 801. Plaintiffs are informed and believe and thereon allege that Defendant 12 Gerard Vangerwen is a resident of the State of California, County of Los Angeles. 13 Defendant has, through counsel, asserted or threatened to assert claims against 14 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 15 802. Plaintiffs are informed and believe, and thereon allege, that defendant 16 Amy Viger is a resident of the State of California. Defendant has previously filed a 17 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 18 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 19 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 20 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 21 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 22 of the County of Los Angeles, State of California. 23 803. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Jeremy Viger is a resident of the State of California. Defendant has previously filed 25 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 26 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 27 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 28 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 39245596.3 -154- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 166 of 181 Page ID #:166 1 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 2 of the County of Los Angeles, State of California. 3 804. Plaintiffs are informed and believe and thereon allege that Defendant 4 Dillon Villalobos is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 805. Plaintiffs are informed and believe and thereon allege that Defendant 8 Don Villalobos is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 806. Plaintiffs are informed and believe and thereon allege that Defendant 12 Lisa Villalobos is a resident of the State of California, County of Los Angeles. 13 Defendant has, through counsel, asserted or threatened to assert claims against 14 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 15 807. Plaintiffs are informed and believe and thereon allege that Defendant 16 Parisse Villalobos is a resident of the State of California, County of Los Angeles. 17 Defendant has, through counsel, asserted or threatened to assert claims against 18 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 19 808. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Peter Violas is a resident of the State of California. Defendant has previously filed a 21 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 22 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 23 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 24 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 25 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 26 of the County of Los Angeles, State of California. 27 809. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Cecelia Joya Walach is a resident of the State of California. Defendant has 39245596.3 -155- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 167 of 181 Page ID #:167 1 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 2 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 3 shooting incident in Las Vegas, Nevada. Based on the allegations in that lawsuit, 4 Abraham, et al. v. MGM, filed November 20, 2017, in the Los Angeles Superior 5 Court (“LASC”), case number BC684047, Plaintiffs are informed and believe that 6 Defendant is a resident of the County of Los Angeles, State of California. 7 810. Plaintiffs are informed and believe, and thereon allege, that defendant 8 Rebecca Waltman is a resident of the State of California. Defendant has previously 9 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 10 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 11 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 12 Los Angeles Superior Court (“LASC”), case number BC684047. 13 811. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Donald Washbrook Jr. is a resident of the State of California. Defendant has 15 previously filed a lawsuit (which was subsequently voluntarily dismissed) against 16 one or more of the Plaintiffs, asserting claims arising from the October 1, 2017, 17 shooting incident in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed 18 November 20, 2017, in the Los Angeles Superior Court (“LASC”), case number 19 BC684047. 20 812. Plaintiffs are informed and believe and thereon allege that Defendant 21 Amanda Wechsler is a resident of the State of California. Defendant has, through 22 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 23 October 1, 2017, shooting incident in Las Vegas, Nevada. 24 813. Plaintiffs are informed and believe and thereon allege that Defendant 25 Carrie Weidenkeller is a resident of the State of California. Defendant has, through 26 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 27 October 1, 2017, shooting incident in Las Vegas, Nevada. 28 39245596.3 -156- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 168 of 181 Page ID #:168 1 814. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Tricia Welch is a resident of the State of California. Defendant has previously filed 3 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 4 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 5 Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 6 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 7 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 8 of the County of Los Angeles, State of California. 9 815. Plaintiffs are informed and believe and thereon allege that Defendant 10 Kevin Wells is a resident of the State of California, County of Los Angeles. 11 Defendant has, through counsel, asserted or threatened to assert claims against 12 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 13 816. Plaintiffs are informed and believe and thereon allege that Defendant 14 Serena West is a resident of the State of California. Defendant has, through counsel, 15 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 16 2017, shooting incident in Las Vegas, Nevada. 17 817. Plaintiffs are informed and believe and thereon allege that Defendant 18 Christopher Wetzel is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 818. Plaintiffs are informed and believe, and thereon allege, that defendant 22 Gina B. Wheeler is a resident of the State of California. Defendant has previously 23 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 24 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 25 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 26 Los Angeles Superior Court (“LASC”), case number BC684047. 27 819. Plaintiffs are informed and believe, and thereon allege, that defendant 28 Derek White is a resident of the State of California. Defendant has previously filed a 39245596.3 -157- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 169 of 181 Page ID #:169 1 lawsuit (which was subsequently voluntarily dismissed) against one or more of the 2 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 3 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 4 Los Angeles Superior Court (“LASC”), case number BC684047. 5 820. Plaintiffs are informed and believe and thereon allege that Defendant 6 Greg White is a resident of the State of California. Defendant has, through counsel, 7 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 8 2017, shooting incident in Las Vegas, Nevada. 9 821. Plaintiffs are informed and believe and thereon allege that Defendant 10 Victoria White is a resident of the State of California. Defendant has, through 11 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 12 October 1, 2017, shooting incident in Las Vegas, Nevada. 13 822. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Presley Wick is a resident of the State of California. Defendant has previously filed 15 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 16 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 17 Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 18 Los Angeles Superior Court (“LASC”), case number BC684047. 19 823. Plaintiffs are informed and believe, and thereon allege, that defendant 20 Tracie P. Wight is a resident of the State of California. Defendant has previously 21 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 22 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 23 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 24 Los Angeles Superior Court (“LASC”), case number BC684047. 25 824. Plaintiffs are informed and believe and thereon allege that Defendant 26 Stacy Wilbanks is a resident of the State of California. Defendant has, through 27 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 28 October 1, 2017, shooting incident in Las Vegas, Nevada. 39245596.3 -158- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 170 of 181 Page ID #:170 1 825. Plaintiffs are informed and believe, and thereon allege, that defendant 2 Rebecca Wilken is a resident of the State of California. Defendant has previously 3 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 4 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 5 in Las Vegas, Nevada, in Mayfield, et al. v. MGM, filed December 15, 2017, in the 6 Los Angeles Superior Court (“LASC”), case number BC687120. 7 826. Plaintiffs are informed and believe and thereon allege that Defendant 8 Anna Williams is a resident of the State of California, County of Los Angeles. 9 Defendant has, through counsel, asserted or threatened to assert claims against 10 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 11 827. Plaintiffs are informed and believe and thereon allege that Defendant 12 Joseph N. Williams is a resident of the State of California, County of Santa Barbara. 13 Defendant has, through counsel, asserted or threatened to assert claims against 14 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 15 828. Plaintiffs are informed and believe and thereon allege that Defendant 16 Stanley Williams is a resident of the State of California. Defendant has, through 17 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 18 October 1, 2017, shooting incident in Las Vegas, Nevada. 19 829. Plaintiffs are informed and believe and thereon allege that Defendant 20 James Williamson is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 830. Plaintiffs are informed and believe, and thereon allege, that defendant 24 Marcus Wilson is a resident of the State of California. Defendant has previously 25 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 26 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 27 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 28 Los Angeles Superior Court (“LASC”), case number BC684047. 39245596.3 -159- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 171 of 181 Page ID #:171 1 831. Plaintiffs are informed and believe and thereon allege that Defendant 2 McKayla Wilson is a resident of the State of California. Defendant has, through 3 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 4 October 1, 2017, shooting incident in Las Vegas, Nevada. 5 832. Plaintiffs are informed and believe and thereon allege that Defendant 6 Katelyn Wing is a resident of the State of California. Defendant has, through 7 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 8 October 1, 2017, shooting incident in Las Vegas, Nevada. 9 833. Plaintiffs are informed and believe, and thereon allege, that defendant 10 Kerry Wisden is a resident of the State of California. Defendant has previously filed 11 a lawsuit (which was subsequently voluntarily dismissed) against one or more of the 12 Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident in 13 Las Vegas, Nevada. Based on the allegations in that lawsuit, Abraham, et al. v. 14 MGM, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case 15 number BC684047, Plaintiffs are informed and believe that Defendant is a resident 16 of the County of Los Angeles, State of California. 17 834. Plaintiffs are informed and believe and thereon allege that Defendant 18 Anthony Wood is a resident of the State of California. Defendant has, through 19 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 20 October 1, 2017, shooting incident in Las Vegas, Nevada. 21 835. Plaintiffs are informed and believe and thereon allege that Defendant 22 Shawna Wood is a resident of the State of California, County of Los Angeles. 23 Defendant has, through counsel, asserted or threatened to assert claims against 24 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. 25 836. Plaintiffs are informed and believe, and thereon allege, that defendant 26 Jaeger Woodson is a resident of the State of California. Defendant has previously 27 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 28 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 39245596.3 -160- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 172 of 181 Page ID #:172 1 in Las Vegas, Nevada. Based on the allegations in that lawsuit, Mayfield, et al. v. 2 MGM, filed December 15, 2017, in the Los Angeles Superior Court (“LASC”), case 3 number BC687120, Plaintiffs are informed and believe that Defendant is a resident 4 of the County of Los Angeles, State of California. 5 837. Plaintiffs are informed and believe and thereon allege that Defendant 6 Jade Wright is a resident of the State of California. Defendant has, through counsel, 7 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 8 2017, shooting incident in Las Vegas, Nevada. 9 838. Plaintiffs are informed and believe and thereon allege that Defendant 10 Jeff Wright is a resident of the State of California. Defendant has, through counsel, 11 asserted or threatened to assert claims against Plaintiffs based upon the October 1, 12 2017, shooting incident in Las Vegas, Nevada. 13 839. Plaintiffs are informed and believe, and thereon allege, that defendant 14 Tome Xayavong is a resident of the State of California. Defendant has previously 15 filed a lawsuit (which was subsequently voluntarily dismissed) against one or more 16 of the Plaintiffs, asserting claims arising from the October 1, 2017, shooting incident 17 in Las Vegas, Nevada, in Abraham, et al. v. MGM, filed November 20, 2017, in the 18 Los Angeles Superior Court (“LASC”), case number BC684047. 19 840. Plaintiffs are informed and believe and thereon allege that Defendant 20 Brett Yeakel is a resident of the State of California. Defendant has, through 21 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 22 October 1, 2017, shooting incident in Las Vegas, Nevada. 23 841. Plaintiffs are informed and believe and thereon allege that Defendant 24 Shawna York is a resident of the State of California. Defendant has, through 25 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 26 October 1, 2017, shooting incident in Las Vegas, Nevada. 27 842. Plaintiffs are informed and believe and thereon allege that Defendant 28 Brandon Young is a resident of the State of California. Defendant has, through 39245596.3 -161- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 173 of 181 Page ID #:173 1 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 2 October 1, 2017, shooting incident in Las Vegas, Nevada. 3 843. Plaintiffs are informed and believe and thereon allege that Defendant 4 Laura Zarate is a resident of the State of California. Defendant has, through 5 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 6 October 1, 2017, shooting incident in Las Vegas, Nevada. 7 844. Plaintiffs are informed and believe and thereon allege that Defendant 8 Shannon Zeeman is a resident of the State of California. Defendant has, through 9 counsel, asserted or threatened to assert claims against Plaintiffs based upon the 10 October 1, 2017, shooting incident in Las Vegas, Nevada. 11 845. Plaintiffs are informed and believe and thereon allege that Defendant 12 Sharla Zotea is a resident of the State of California, County of Los Angeles. 13 Defendant has, through counsel, asserted or threatened to assert claims against 14 Plaintiffs based upon the October 1, 2017, shooting incident in Las Vegas, Nevada. JURISDICTION AND VENUE 15 16 846. This Court has subject-matter jurisdiction pursuant to 28 U.S.C. § 1331 17 and 6 U.S.C. §442(a). As alleged hereinabove, the SAFETY Act expressly provides 18 for original and exclusive federal jurisdiction over actions arising from or relating to 19 acts of mass violence where technologies or services certified by the Secretary of 20 Homeland Security were deployed. At the time of Paddock’s mass attack at the 21 Route 91 concert, security services were provided by Contemporary Services 22 Corporation as the Security Vendor for the Route 91 Harvest Festival. CSC’s 23 security services were certified by the Secretary of Homeland Security under the 24 SAFETY Act. 25 847. In addition, the Court has subject-matter jurisdiction pursuant to 28 26 U.S.C. § 1332 in that Plaintiffs (by virtue of their incorporation and principal places 27 of business) are citizens of the States of Delaware and Nevada; Defendants are 28 citizens of the State of California; and as to some Defendants, the matter in 39245596.3 -162- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 174 of 181 Page ID #:174 1 controversy exceeds, exclusive of interest and costs, the sum specified by 28 U.S.C. 2 § 1332(a). As to Defendants whose claims individually do not meet the amount-in3 controversy threshold of 28 U.S.C. § 1332(a), this Court has supplemental 4 jurisdiction over such claims under 28 U.S.C. § 1367 because those claims are so 5 related to claims of parties whose claims do meet the amount-in-controversy 6 threshold of 28 U.S.C. § 1332(a) that they form part of the same case of controversy 7 under Article III of the United States Constitution, because all claims arise out of the 8 same occurrence, viz., the mass attack perpetrated by Stephen Paddock at the Route 9 91 Harvest Festival in Las Vegas on October 1, 2017. 10 848. This Court has personal jurisdiction over defendants because they are 11 residents of the State of California and are therefore subject to the general personal 12 jurisdiction of this Court. 13 849. Venue is proper in this Judicial District pursuant to 28 U.S.C. 14 § 1391(b)(1) because one or more of the Defendants are known to reside, or upon 15 information and belief, do reside, within this Judicial District. 16 FIRST CAUSE OF ACTION FOR DECLATORY RELIEF 17 (By Plaintiffs against all Defendants) 18 850. Plaintiffs reallege and incorporate by reference, as though fully set 19 forth, the allegations of paragraphs 1-849, above. 20 851. Following Paddock’s mass attack on the concert, over 2,500 21 individuals have either sued the MGM Parties, or threatened to sue the MGM 22 Parties, for claims alleged to arise from or relate to Paddock’s attack. Several 23 hundred individuals filed suit, and before the issues could be joined or resolved, 24 they dismissed their claims, apparently with the intent of refiling. 25 852. Each Defendant either (a) has previously filed suit (and then dismissed 26 it) against one or more of the MGM Parties relating to the Paddock attack, or (b) 27 through counsel has stated an intention to sue the MGM Parties relating to the 28 39245596.3 -163- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 175 of 181 Page ID #:175 1 attack. There is no pending litigation between Plaintiffs and Defendants relating to 2 the attack. 3 853. The claims alleged in the now-dismissed lawsuits include claims of 4 alleged negligence by the MGM Parties and others, including CSC, in protecting 5 and safeguarding persons including those Defendants who attended the Route 91 6 Festival. 7 854. Defendants’ actual and threatened lawsuits implicate the services 8 provided by CSC because they implicate security at the concert, including training, 9 emergency response, evacuation and adequacy of egress. 10 855. These claims are subject to the SAFETY Act, because (a) they arise 11 from and relate to an act of mass violence meeting the statutory requirements; (b) 12 CSC provided security at the concert, deploying services certified by the 13 Department of Homeland Security under the SAFETY Act to protect against or 14 respond to such an attack; and (c) the claims may therefore result in loss to CSC as 15 the “Seller” of such certified services. 16 856. The claims threatened against the MGM Parties by certain Defendants, 17 through counsel, also inevitably fall under the SAFETY Act for the very same 18 reasons: (a) they arise from and relate to an act of mass violence meeting the 19 statutory requirements; (b) CSC provided security at the concert, deploying services 20 certified by the Department of Homeland Security under the SAFETY Act to protect 21 against or respond to such an attack; and (c) the claims may therefore result in loss 22 to CSC as the “Seller” of such certified services. If Defendants were injured by 23 Paddock’s assault, as they allege, they were inevitably injured both because 24 Paddock fired from his window and because they remained in the line of fire at the 25 concert. Such claims inevitably implicate security at the concert—and may result in 26 loss to CSC. 27 857. The SAFETY Act applies to claims “arising out of, relating to, or 28 resulting from an act of terrorism.” 39245596.3 -164- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 176 of 181 Page ID #:176 1 858. The SAFETY Act defines an act of terrorism: An act meets the 2 requirements if the act is (i) “unlawful” (ii) “causes harm to a person … in the 3 United States,” and (iii) “uses or attempts to use … weapons … designed or 4 intended to cause mass … injury.” 6 U.S.C. § 444(2)(B). There is no requirement 5 in the statute or regulations of an ideological motive or objective for the attack for it 6 to meet the requirements of the SAFETY Act. 7 859. Paddock’s mass attack satisfies the requirements of the SAFETY Act 8 and the regulations: (i) it was “unlawful,” (ii) it resulted in death or injury to 9 hundreds of persons in the United States, and (iii) it involved weapons and other 10 instrumentalities that were designed and intended to cause, and which in fact caused, 11 mass injury and death. Those weapons and instrumentalities included rifles 12 modified with bump stocks to spray fully automatic gun fire; high-capacity 13 magazines capable of holding between 60 and 100 rounds; and illegal incendiary 14 rounds intended to blow up the fuel tanks adjacent to the concert. Paddock used 15 these weapons and instrumentalities to fire hundreds of rounds at the crowd, and he 16 fired incendiary rounds which struck the fuel tanks but, fortunately, missed the fuel. 17 860. The post-attack investigation revealed that Paddock brought in his van, 18 which he parked in the hotel garage, 90 pounds of explosives, consisting of 20 two19 pound containers of exploding targets, 10 one-pound containers of exploding targets 20 and 2 twenty-pound bags of explosive precursors. 21 861. No MGM Party attempted to commit, knowingly participated in, aided, 22 abetted, committed, or participated in any conspiracy to commit any act of terrorism 23 of criminal act related to mass attack perpetrated by Stephen Paddock at the Route 24 91 Harvest Festival in Las Vegas, Nevada, on October 1, 2017. 25 862. The Secretary of Homeland Security may make a determination that 26 conduct in question meets the statutory requirement, but neither the Act nor the 27 regulations requires a formal certification. The Statute provides that the Secretary 28 shall have exclusive authority to certify services, but the authority to determine 39245596.3 -165- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 177 of 181 Page ID #:177 1 whether an act of mass violence meets the statutory requirements is not exclusive to 2 the Secretary. 3 863. Public statements by the Secretary of Homeland Security concerning 4 the attack make clear that the attack meets the requirements of the SAFETY Act; 5 indeed, based on the plain language of the statute, the regulations, and the facts, no 6 other determination could be possible. 7 864. In congressional testimony on November 30, 2017, the Acting 8 Secretary of Homeland Security noted the emphasis of “terrorists and other violent 9 criminals … on attacking soft targets,” including “recent tragedies in Nevada.” The 10 Acting Secretary went on to note that the “SAFETY Act Program” “provide[s] 11 critical incentives for the development and deployment of anti-terrorism 12 technologies by providing liability protections for ‘qualified anti-terrorism 13 technologies,’” which applies to a number of large sports and entertainment venues 14 nationwide. 15 865. In a May 2018 release, Department of Homeland Security noted that 16 “mass shootings” in various places, including at a “concert,” aim “to kill and maim 17 unsuspecting individuals” and thereby fall within the Department’s “primary 18 mission” “to prevent terrorist attacks within the U.S, reduce the vulnerability of the 19 U.S. to terrorism, and minimize the damage and assist in the recovery from terrorist 20 attacks that do occur, including those in ST-CPs [soft-targets-crowded places].” 21 Department of Homeland Security, Soft Targets and Crowded Places Security Plan 22 Overview, May 2018, at page 2. The report goes on to note that the protections of 23 the SAFETY Act have been “approved for open venues such as sports arenas and 24 stadia” – such as the venue for the Route 91 Festival. Id. at p. 17. 25 866. The Department continues its critical work to prevent and respond to 26 mass violence. In Congressional testimony on May 15, 2018, the Secretary testified 27 that DHS is “seeking to ramp up ‘soft target’ security efforts,” noting that DHS 28 programs “address threats to soft targets – including schools, entertainment venues, 39245596.3 -166- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 178 of 181 Page ID #:178 1 major events, and public spaces” (emphasis added). Further, on June 4, 2018, DHS 2 announced that it had “developed a ST-CP Security Enhancement and Coordination 3 Plan,” which has not been made public. The plan addresses “the increased emphasis 4 by terrorists and other extremist actors to leverage less sophisticated methods to 5 inflict harm in public areas … such as parks, … special event venues, and similar 6 facilities.” See https://www.dhs.gov/publication/securing-soft-targets-and-crowded7 spaces (emphasis added). 8 867. The SAFETY Act creates a single, exclusive federal cause of action for 9 claims for injuries arising out of or relating to acts of mass violence where services 10 certified by the Department of Homeland Security were deployed in defense against, 11 response to, or recovery from such act and such claims result or may result in loss to 12 the Seller. 13 868. Pursuant to the SAFETY Act, the Department of Homeland Security 14 has certified the services provided by CSC. The DHS Certification recognizes 15 CSC’s security services as appropriate for preventing and responding to acts of mass 16 violence. 6 U.S.C. § 441; see also 48 C.F.R. § 50.201. 17 869. CSC’s security services Certified by DHS include “Physical Security”; 18 “Access Control”; and “Crowd Management.” 19 870. CSC’s Certified Crowd Management Services include: 20 • “Awareness of venue-specific emergency response protocols and 21 evacuation procedures to include emergency alert and mass-notification systems and 22 sheltering procedures”; 23 • “Pre-event venue / event safety inspections”; 24 • “Facilitation of crowd movement during ingress, circulation, sheltering 25 in place, emergency evacuations, and egress”; 26 • “Pre-event coordination and multi-agency collaboration with public 27 safety agencies”; 28 • 39245596.3 “Selection, vetting, and training of employees.” -167- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 179 of 181 Page ID #:179 1 871. As alleged above, CSC was employed as the Security Vendor for the 2 Route 91 concert. CSC’s responsibilities at the Route 91 Harvest Festival included 3 providing the following DHS Certified Services: 4 • “perimeter security, event access, festival grounds event security”; 5 • “Staff[ing] inner perimeter and gates”; 6 • “Protect[ing] against unauthorized access”; 7 • “early warning … of perimeter breaches”; 8 • “Secur[ing] internal festival grounds”; 9 • “Patrol[ing] festival floor grounds and assist[ing] patrons with any 10 security related issues”; 11 • pre-event planning for “Security and Safety”; 12 • “Emergency response” and “evacuation,” including evacuation for 13 “terrorist threat” and “ensur[ing] that the exit routes and gates remain unobstructed.” 14 872. For the reasons set forth above, the SAFETY Act creates an exclusive 15 cause of action for any claims arising out of relating to Paddock’s mass attack and 16 such claims may result in loss to the Seller. Under the SAFETY Act, there “shall 17 exist only one cause of action for loss of property, personal injury, or death. 6 18 C.F.R. 25.7 (d). 19 873. Such cause of action “may be brought only against the Seller of the 20 Qualified Anti-Terrorism Technology and may not be brought against the buyers, 21 the buyer’s contractors, or downstream users of the Technology, the Seller’s 22 suppliers or contractors, or any other person or entity.” 6 C.F.R. 25.7 (d). The 23 SAFETY Act precludes any liability on the part of Plaintiffs to Defendants relating 24 to Paddock’s mass attack. 25 874. In addition, the SAFETY Act provides that for any covered claims 26 arising out of or relating to an act of mass violence where certified services were 27 provided, “the government contractor defense applies in such a lawsuit,” which 28 provides a complete defense to liability. 6 U.S.C. 442(d)(1). The government 39245596.3 -168- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 180 of 181 Page ID #:180 1 contractor defense precludes any finding of liability on the part of Plaintiffs to 2 Defendants relating to Paddock’s mass attack. 3 875. An actual and justiciable controversy exists between Plaintiffs and 4 Defendants concerning the applicability of the SAFETY Act. Plaintiffs assert that 5 the SAFETY Act precludes any liability for any claims arising out of or relating to 6 Paddock’s mass attack, whereas, on information and belief, Defendants deny that 7 the Act applies or that it precludes liability on their claims against Plaintiffs. 8 876. A judicial declaration as to whether the SAFETY Act applies and 9 precludes liability on Defendants’ claims against the Plaintiffs is necessary at this 10 time so that the parties may ascertain their rights, and avoid the significant judicial 11 waste that would occur if the lawsuits were allowed to proceed in the absence of a 12 finding as to the applicability of the SAFETY Act. PRAYER FOR RELIEF 13 14 WHEREFORE, Plaintiffs MGM Parties pray for judgment against 15 Defendants, and each of them, as follows: 1. 16 For a judicial declaration that: 17 a. Defendants’ claims arising from the attack by Stephen Paddock on 18 October 1, 2017 in Las Vegas, Nevada are subject to and governed by 19 the SAFETY Act, 6 U.S.C. § 441 et seq.; 20 b. the SAFETY Act precludes any finding of liability against Plaintiffs 21 for any claim for injuries arising out of or related to Paddock’s mass 22 attack, without prejudice to Defendants’ rights to pursue claims against 23 the “Seller” under the Act, including to obtain proceeds of insurance 24 that any such Seller was required by the Act to maintain; c. Plaintiffs have no liability of any kind to Defendants, or any of them, 25 arising from the Paddock’s mass attack; and 26 27 2. 28 just and proper. 39245596.3 For such other and further legal or equitable relief as the Court deems -169- COMPLAINT FOR DECLARATORY RELIEF Case 2:18-cv-06113-JAK-E Document 1 Filed 07/13/18 Page 181 of 181 Page ID #:181 1 DATED: July 13, 2018 2 3 MUNGER, TOLLES & OLSON LLP BRAD D. BRIAN MICHAEL R. DOYEN BETHANY W. KRISTOVICH 4 5 By: 6 7 /s/ Michael R. Doyen MICHAEL R. DOYEN Attorneys for Plaintiffs MGM RESORTS INTERNATIONAL, MANDALAY RESORT GROUP, MANDALAY BAY, LLC, MGM RESORTS FESTIVAL GROUNDS, LLC, and MGM RESORTS VENUE MANAGEMENT, LLC 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 39245596.3 -170- COMPLAINT FOR DECLARATORY RELIEF