Electronically FILED by Superior Court of California, County of Los Angeles on 09/23/2020 10:50 AM Sherri R. Carter, Executive Officer/Clerk of Court, by N. Alvarez,Deputy Clerk

20STCV36391
Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: Monica Bachner

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ANDREW BAUM - State Bar No. 190397
abaum@glaserweil.com
JESSE B. LEVIN - State Bar No. 268047
jlevin@glaserweil.com
GLASER WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
Telephone: (310) 553-3000
Facsimile: (310) 556-2920
Attorneys for Plaintiff
Bryan Callen

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

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FOR THE COUNTY OF LOS ANGELES

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BRYAN CALLEN, an Individual,

Case No.

Plaintiff,
v.
GABRIEL TIGERMAN, an Individual, and
DOES 1-10,
Defendants.

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Unlimited Jurisdiction
COMPLAINT FOR INTENTIONAL
INTERFERENCE WITH
CONTRACTUAL RELATIONS
DEMAND FOR JURY TRIAL

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Plaintiff Bryan Callen alleges as follows:
NATURE OF THE ACTION
1.

This lawsuit arises from Defendant Gabriel Tigerman’s ongoing campaign to destroy

the livelihood of actor and stand-up comic Bryan Callen through threats, harassment, and
intimidation of third parties that dare contract with him. Driven by the false allegation that
Mr. Callen assaulted his wife over 20 years ago, Mr. Tigerman has sent and continues to send
Mr. Callen’s representatives and others direct demands that they cease doing business with him, or
else be falsely branded as supporters of sexual assault.
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COMPLAINT FOR INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS

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As a direct result of Mr. Tigerman’s vengeful interference, Mr. Callen’s agents

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dropped him and comedy clubs have cancelled contracts to perform. This is illegal, wrong, and

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without regard for due process.
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By this Complaint, Mr. Callen simply seeks to preserve his ability to work and earn a

living.
PARTIES

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4.

Plaintiff Bryan Callen is an entertainer who makes his living as a film and television

actor, writer, podcaster, and a stand-up comic. He resides in the County of Los Angeles.
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Upon information and belief, Plaintiff alleges that Defendant Gabriel Tigerman is an

individual residing in the County of Los Angeles.
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Upon information and belief, Plaintiff alleges that each of the fictitiously named Doe

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Defendants is responsible in some manner for the occurrences herein alleged, and that Callen’s

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damages as herein alleged were actually and proximately caused by their conduct.

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7.

Upon information and belief, Plaintiff alleges that at all material times, each

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Defendant was the agent, servant, authorized representative, predecessor, successor, co-conspirator,

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employer and/or employee of each other, and in doing the things and acts alleged in this Complaint,

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was acting within the course and scope of said relationship(s); and further, that each Defendant has

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authorized, approved, ratified and/or endorsed the acts of each remaining Defendant. Further, each

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of the Defendants was a partner, or was engaged in a joint venture with one or more of the remaining

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Defendants, and was acting within the scope and purpose of said partnership or joint venture. Each

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Defendant has ratified each and every act of each other Cross-Defendant pertinent to said partnership

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or joint venture.
JURISDICTION AND VENUE

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8.

The events or occurrences giving rise to the claims alleged in the Complaint took

place in the County of Los Angeles.
9.

Pursuant to Article VI, Section 10 of the California Constitution and § 410.10 of the

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Code of Civil Procedure, subject matter jurisdiction is proper in the Superior Court of California for

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the County of Los Angeles.

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COMPLAINT FOR INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS

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10.

Pursuant to § 395 of the Code of Civil Procedure, venue is proper in the Superior

Court for the County of Los Angeles.
FACTS COMMON TO ALL CAUSES OF ACTION

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Plaintiff Bryan Callen is a well-known actor and comedian, who got his first break as

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part of original cast of the hit late-night show, MADtv in 1995. In the years since, he has regularly

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appeared in film and television and toured as a stand-up comic.

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12.

To perform as a stand-up comic, Plaintiff Bryan Callen contracts with various comedy

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club venues and live theater chains across the country. The identity of these venues is public

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knowledge because Mr. Callen publishes his tour schedule on his website, BryanCallen.com.

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13.

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Agency (“CAA”).

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14.

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To procure work as a stand-up comic, Mr. Callen contracted with Creative Artists

To procure acting roles, Mr. Callen contracted with Innovative Artists Talent and

Literary Agency, Inc. (“Innovative Artists”).
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At all relevant times, Mr. Callen’s representation was public knowledge. Anyone,

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including Defendant, could find his agents’ contact information at CAA and Innovative Artists on

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numerous websites via a simple Google search.

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16.

On July 31, 2020, the Los Angeles Times published an article wherein Katherine Fiore

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Tigerman accused Mr. Callen of raping her 21 years ago. Defendant Gabriel Tigerman is married to

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Katherine Fiore Tigerman.

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17.

Mr. Callen never assaulted Mrs. Tigerman. All of the allegations of Mr. Callen’s

misconduct published in the LA Times are false. And Mr. Callen has publicly denied them.

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18.

Moreover, Mr. Callen has never been charged with nor convicted of sexual assault.

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19.

Twenty days after the publication of LA Times article, Defendant Gabriel Tigerman

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sent Mr. Callen’s representatives a demand that they drop Mr. Callen as a client. In particular, on

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August 20, 2020, Mr. Tigerman sent an email to CAA stating:

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“My name is Gabriel Tigerman. I am sure you are aware of the heavily vetted rape
and sexual assault allegations against your client, Bryan Callen, detailed on the front
page of the LA Times a few weeks ago. Four women came forward for this article.
My wife, Katherine Fiore Tigerman, is one of them. Bryan Callen raped her twenty
years ago. I know CAA dropped Bryan’s close friend and partner, Chris D’Elia, when
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COMPLAINT FOR INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS

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the LA Times reported of his sexual predation. I can only assume his representatives
knew that, by continuing to represent D’Elia, they would be standing with abusers
and would be sending the message to victims that this behavior is okay. I am
writing to find out what the status is with Callen at CAA. Do you and CAA still
represent this serial sexual predator? I hope the answer is no.
(Emphasis added).

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20.

Upon information and belief, Plaintiff alleges that Gabriel Tigerman sent this email

or one like it to Innovative Artists on or around the same day.

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21.

As a result, one day after receiving Mr. Tigerman’s email, both CAA and Innovative

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Artists quit representing Mr. Callen, and refused to continue to procure him acting and comedy work

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pursuant to contract.

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The loss of Mr. Callen’s representation contracts forecloses the possibility of future

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acting and performance jobs that only a licensed talent agency can procure on his behalf. The

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resulting loss of future earnings to Mr. Callen is immense.

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23.

Gabriel Tigerman continues to communicate similar harassing and threatening

messages to other parties with whom Mr. Callen has contracted or has a business relationship.

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24.

For instance, in September 2020, Mr. Tigerman called and wrote various comedy

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venues with whom Mr. Callen was contracted to perform in October and November, including

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Bricktown Comedy Club in Oklahoma City, Oklahoma and Skyline Comedy Club in Appleton,

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Wisconsin. Mr. Tigerman told these venues that by not cancelling their contracts with Mr. Callen,

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they were sending the message that they support sexual abusers and do not believe victims of sexual

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assault.

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Following Mr. Tigerman’s communications, the Bricktown Comedy Club and

Skyline Comedy Club cancelled Mr. Callen’s contracts to perform at their venues.
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In sum, Mr. Tigerman has engaged in a relentless campaign of economic interference

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against Mr. Callen as revenge for something Mr. Callen did not do. Mr. Tigerman’s apparent

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objective is to have Mr. Callen blacklisted, destitute, never to work again.

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27.

The direct impact has been nothing short of devastating to Mr. Callen personally and

financially.
28.

Mr. Callen’s growing damages are well in excess of the jurisdictional requirement of

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this Court.

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29.

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By this Complaint, Mr. Callen seeks to halt Mr. Tigerman’s misconduct and be made

whole for the undue harm it has inflicted on his entertainment career.

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CAUSE OF ACTION

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(Intentional Interference with Contractual Relations)

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(Against All Defendants)

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30.

Plaintiff Bryan Callen refers to and incorporates by reference all of the allegations in

Paragraphs 1 through 29, as if fully restated herein.
31.

There were contracts between Mr. Callen and the following entities:

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a. Creative Arts Agency;

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b. Innovative Artists Talent and Literary Agency, Inc.;

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c. Bricktown Comedy Club; and

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d. Skyline Comedy Club.

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32.

Defendants knew of these contracts.

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33.

Defendants’ conduct prevented performance or made performance more difficult for

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each of these contracts.
34.

By, among other things, communicating demands that the third parties stop

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contracting with Mr. Callen, sending harassing and intimidating messages, and threatening to

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publicly brand the third parties as supporting perpetrators of sexual assault, Defendants intended to

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disrupt the performance of these contracts or knew that disruption of performance was certain or

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substantially certain to occur.

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35.

Plaintiff Bryan Callen was harmed.

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36.

Defendants’ conduct was a substantial factor in causing Mr. Callen’s harm.

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37.

Mr. Callen has suffered, and will suffer in the future, damages in an amount to be

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proven at trial.
38.

Defendants’ conduct, as set forth above, was and is willful, malicious, fraudulent,

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oppressive, outrageous, and committed with the conscious and reckless disregard to the

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consequences, thus justifying punitive and exemplary damages against Defendants in an amount

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sufficient to punish Defendants for the severity of their conduct.
PRAYER

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For actual damages according to proof at trial;

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2.

For pre-judgment interest on all such damages at the legal rate;

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3.

For punitive damages according to proof at trial in an amount sufficient to punish

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and make an example of Defendants for their wrongful conduct;

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4.

For attorneys’ fees as permitted by law;

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5.

For costs of suit; and

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6.

For such other relief as the Court deems just and proper.

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DATED: September 23, 2020

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GLASER WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
By:

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ANDREW BAUM
JESSE B. LEVIN
Attorneys for Plaintiff
Bryan Callen

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DEMAND FOR JURY TRIAL
Plaintiff Bryan Callen hereby demands a jury trial on all issues.
DATED: September 23, 2020

GLASER WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
By:

ANDREW BAUM
JESSE B. LEVIN
Attorneys for Plaintiff
Bryan Callen

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COMPLAINT FOR INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS