Jimmy Safechuck – The Civil Complaint

FIRST AMENDED COMPLAINT FOR CHILDHOOD SEXUAL ABUSE:

(1) Childhood Sexual Abuse [CCP § 340.1]
(2) Negligence
(3) Negligent Infliction of Emotional Distress
(4) Breach of Fiduciary Duty

DEMAND FOR JURY TRIAL

Michael Jackson & Jimmy Safechuck
Michael Jackson & Jimmy Safechuck

Plaintiff JAMES SAFECHUCK (“Plaintiff’) hereby alleges against Defendants MJJ PRODUCTIONS, INC., MJJ VENTURES, INC., and Does 4 through 50, inclusive (“Defendants”) as follows:

FIRST CAUSE OF ACTION

(Childhood Sexual Abuse [CCP § 340.1] as to all Defendants)

PARTIES

1. Plaintiff is a thirty-seven (37) year old male individual and resident of the County of Los Angeles, State of California.
2. Michael Jackson (hereafter :”DECEDENT”) was previously fictitiously identified herein and in related pleadings as Doe 1 for purposes of alleging his actions without identifying him by name and to place into context the actions and/or status of the Defendants. He was fictitiously identified in an effort to comply with the spirit and intent of confidentiality required by California Code of Civil Procedure (“CCP”) §340.1. DECEDENT is now identified by name consistent with prior Court orders. DECEDENT was one of the most famous and successful entertainers in pop music history. Plaintiff is informed, believes, and thereupon alleges that, at all times relevant herein, DECEDENT was a resident of the State of California and maintained residences in the Counties of Los Angeles and Santa Barbara. Plaintiff is further informed and believes, and thereupon alleges, that DECEDENT died in Los Angeles, California on June 25, 2009, at the age of fifty (50).
3. Plaintiff is informed and believes, and thereupon alleges, that Defendant MJJ PRODUCTIONS, INC. (“MJJ PRODUCTIONS”) is a California corporation, with a principal place of business located in the County of Los Angeles, State of California. Plaintiff is further informed and believes, and thereupon alleges, that at all times relevant herein, MJJ PRODUCTIONS was a company established by DECEDENT as his primary business entity and the entity that held most or all of the copyrights to DECEDENT’s music and videos. Plaintiff is further informed and believes, and thereon alleges, that DECEDENT was the president/owner and a representative/agent of MJJ PRODUCTIONS at all times relevant herein, and that in that capacity, MJJ PRODUCTIONS had the ability to exercise control over DECEDENT’s business and personal affairs. Plaintiff is further informed and believes, and thereon alleges, that DECEDENT, with MJJ PRODUCTIONS’ full knowledge, consent, and assistance, exploited this relationship with MJJ PRODUCTIONS to, gain access to Plaintiff, and to set up, facilitate and arrange meetings and encounters between DECEDENT and Plaintiff for the purpose of DECEDENT’s engaging in childhood sexual abuse of Plaintiff.
4. Plaintiff is informed and believes, and thereupon alleges, that Defendant MJJ VENTURES, INC. (“MJJ VENTURES”) is a California corporation, with a principal place of business located in the County of Los Angeles, State of California. Plaintiff is further informed and believes, and thereupon alleges, that at all times relevant herein, MJJ VENTURES was a company established by DECEDENT in part for the puipose of employing Plaintiff to work with DECEDENT on various projects, and further, that DECEDENT was the president/owner and a representative/agent ofMJJ VENTURES at all times relevant herein, and that in that capacity,
MJJ VENTURES had the ability to exercise control over DECEDENT’s personal and business affairs. Plaintiff is further informed and believes, and thereon alleges, that DECEDENT, with MJJ VENTURES’ full knowledge, consent, and assistance, exploited this relationship to gain access to Plaintiff, and to set up, facilitate, and arrange.meetings and encounters between DECEDENT and Plaintiff for the purpose of DECEDENT engaging in childhood sexual abuse of Plaintiff.
5. In performing the acts complained of herein, DECEDENT acted with the full knowledge, consent and cooperation of MJJ PRODUCTIONS and MJJ VENTURES, who were
his co-conspirators, collaborators, facilitators and alter egos for the childhood sexual abuse alleged herein. As a result thereof, Defendants MJJ PRODUCTIONS and MJJ VENTURES are liable for DECEDENT’s acts of childhood sexual abuse within the meaning of CCP §§ 340.1 (a)(2) and (3 ), and 340.1 (b )(2), in that said entities owed a duty of care to the Plaintiff, and their wrongful, intentional and/or negligent acts, as well as knowing failure to take reasonable steps and implement reasonable safeguards to avoid acts of unlawful sexual conduct by DECEDENT, were a legal cause of the childhood sexual abuse which resulted in injury to Plaintiff as alleged herein.
6. Plaintiff is informed and believes, and thereupon alleges, that the true names and capacities, whether individual, corporate, associate or otherwise, of Defendants named herein as DOES 4 through 50, inclusive, are unknown to Plaintiff, who therefore sues said Defendants by such fictitious names. Plaintiff will amend this First Amended Complaint to allege their true names and capacities when such have been ascertained. Upon information and belief, each of the said Doe Defendants is responsible in some·manner under CCP §§ 340.1(a)(2) and (3), and 340.1(b)(2) for the occurrences herein alleged, and their actions were a direct and legal cause of the childhood sexual abuse which resulted in injury to the Plaintiff as alleged herein.

FACTUAL ALLEGATIONS

7. Plaintiff was born in Simi Valley, California on February 28, 1978. Plaintiff started working in television commercials at the age of 7-8 in approximately 1984/1985. In late 1986/early 1987, Plaintiff was hired to work on a Pepsi commercial that featured DECEDENT in a starring role. Plaintiffs mother accompanied him on the Pepsi commercial shoot. Karen Faye, DECEDENT’s hairstylist, was present at the shoot and for the first conversation between Plaintiff and DECEDENT in DECEDENT’s trailer. Following that conversation, DECEDENT asked Plaintiff to sit on the stage and watch as DECEDENT performed for the commercial shoot.
8. Several months after the Pepsi commercial was shot, DECEDENT wrote a letter to Plaintiff on MJJ PRODUCTIONS’ stationery, dated March 10, 1987. It stated:

Jimmy received a letter from Michael
Jimmy received a letter from Michael

“DEAR JIMMY,
THANK YOU FOR YOUR LETTER. IT WAS NICE HEARING FROM YOU AGAIN!
I’VE BEEN WORKING ON A NEW VIDEO FOR MY ALBUM AND HAVE BEEN REALLY BUSY.
IT WAS FUN WORKING WITH YOU ON THE PEPSI COMMERCIAL! MAYBE WE CAN WORK TOGETHER AGAIN. I’D LIKE TO HAVE YOU COME AND VISIT ME ON THE SET SOMETIME OR WHEN I HAVE SOME FREE TIME YOU CAN COME TO MY HOUSE.
KEEP SENDING ME LETTERS! I LOVE TO HEAR FROM YOU!
SPEAK WITH YOU SOON, [DECEDENT’S signature]”

The DECEDENT also enclosed photographs from the Pepsi commercial that they shot together.
9. After receiving DECEDENT’s letter, Plaintiff and his family were invited to dinner by DECEDENT to DECEDENT’s home on Hayvenhurst Avenue in Encino, California (“Hayvenhurst house”). The invitation was made by DECEDENT through Jolie Levine, DECEDENT’s then secretary/personal assistant and an employee of MJJ PRODUCTIONS. Ms. Levine later became DECEDENT’s produCtion assistant on the “BAD” Tour, and his production coordinator on the “BAD” album. Plaintiffs parents accompanied him to DECEDENT’s Hayvenhurst house for the dinner. After eating, all four of them watched the film Batteries Not Included in a small home theater in DECEDENT’s Hayvenhurst house. During that visit, when DECEDENT was alone with Plaintiff, DECEDENT gave Plaintiff presents- a globe and $700. Plaintiffs parents were not aware that DECEDENT had given their son money at the time, and when they discovered it later, they asked DECEDENT not to give Plaintiff money. In response to their request, DECEDENT giggled and said that he could not help himself.
10. Shortly after their first visit to the Hayvenhurst house, on Thanksgiving Day, Plaintiff was on the telephone with DECEDENT. Plaintiffs parents suggested that he invite DECEDENT to come over to their home. DECEDENT said yes, and Plaintiff and his parents drove over to the Hayvenhurst house to pick up DECEDENT and bring him back to their home. On multiple occasions after the first visit to the Havenhurst house, either Plaintiff and his family, or Plaintiff on his own, would go over to see DECEDENT at the Hayvenhurst house.
11. On the second occasion that Plaintiff went to the Hayvenhurst house, Plaintiff was dropped off by his parents. Plaintiffs parents went to dinner while Plaintiff stayed with DECEDENT. Plaintiff and _DECEDENT drove off in DECEDENT’s Mercedes and passed out $100 bills to homeless people. DECEDENT said to one homeless man, “You do know how much this is,” and then handed him a $100 bill.
12. The third time Plaintiff visited the Hayvenhurst house he was accompanied by his parents and they took a tour of DECEDENT’s recording studio which was located there. Three of DECEDENT’s brothers were in the studio working, including Jermaine Jackson, and they all exchanged a quick hello.
13. During his many visits to the Hayvenhurst house, Plaintiff would “hang out” with the DECEDENT in DECEDENT’s bedroom, and spend time with him in DECEDENT’s dance room. There was a staircase leading to DECEDENT’s bedroom on the exterior of the Hayvenhurst house so that one could enter it from the outside. The upstairs portion of DECEDENT’s bedroom overlooked the main, downstairs portion of his bedroom. It was reachable by a spiral staircase from the main part of the bedroom below. DECEDENT kept the mannequins that he collected in the upstairs portion of the bedroom, and positioned them so that they looked down to the lower portion. Plaintiff and DECEDENT played with the mannequins on Plaintiffs many visits. The main, downstairs portion of DECEDENT’s bedroom had a giant globe that was lit from the inside. DECEDENT had a closet located in the upstairs portion of his bedroom on the left side that he kept filled with jackets from his past music videos and performances. DECEDENT let Plaintiff touch and play with his many jackets. DECEDENT let Plaintiff try on the “Captain EO” jacket, and gave him the Thriller jacket to keep. DECEDENT took back the Thriller jacket a few years later, saying that the jacket would still belong to the Plaintiff, but that he needed to display it at a museum. DECEDENT told Plaintiff that there would be a plaque saying “on loan from Jimmy Safechuck.” In the meantime, DECEDENT let
Plaintiff choose between two. of the other jackets used in the Thriller video–the “Zombie” jacket and the “clean” one.
14. DECEDENT began telephoning Plaintiff at home on a frequent and regular basis. Their relationship had grown to a point where DECEDENT had become part of Plaintiffs family. DECEDENT would call Plaintiff at home when he was alone or lonely, and Plaintiffs family would drive over to the Hayvenhurst house and pick up DECEDENT and bring him back to Plaintiffs home in Simi Valley. Onetime Plaintiff and DECEDENT went to the park in Simi Valley. They shot some video footage there that ended up in the closing credits of one of DECEDENT’s documentaries. On another occasion, Plaintiff and DECEDENT went to the Zales jewelry store in Simi Valley. DECEDENT was wearing a disguise and the salesperson at the Zales store called the police. When the police arrived and saw that it was DECEDENT, they did not pursue the matter. On another occasion, Plaintiffs father picked up DECEDENT from the Hayvenhurst house, and they had to drive away quickly in order to evade the paparazzi. Plaintiff and his family viewed this to be exciting- as was the entire experience of being with a “star” with such celebrity status as DECEDENT: At this time DECEDENT was in his late 20’s, Plaintiff was approximately 8-9 years old, and Plaintiffs parents were in their 40’s.

p18nq5h7go1f5gh7u1edp1dn616pc215. In 1988, when Plaintiff was 10 years old and DECEDENT was 29-30 years old, DECEDENT invited Plaintiff to a convention in Hawaii at which the Pepsi commercial they had both appeared in was being featured. Plaintiff attended the Pepsi convention with DECEDENT and appeared with him on stage. DECEDENT and/or MJJ PRODUCTIONS and MJJ VENTURES made all the arrangements and paid· all the ·expenses for Plaintiff and his mother to fly first class to Hawaii, travel by limousine to the Kahala Hilton Hotel and for all of their accommodations and expenses during the convention. Plaintiff and his mother travelled together with DECEDENT’s entourage. Plaintiff stayed with his mother in her hotel room on that trip. On later trips, when Plaintiff travelled with DECEDENT, his parents would never have a room near DECEDENT’s room, and would be on a different floor.
16. During the convention, Plaintiff spent a great deal of time with DECEDENT and got to know him well, and their friendship deepened. On this trip, DECEDENT asked if Plaintiff could sleep over in his room, but Plaintiffs mother did not permit it. This was the first time DECEDENT asked if Plaintiff could “sleep over” in his room.
17. While they were in Hawaii, DECEDENT rented a helicopter to take Plaintiff and his mother on a tour. Plaintiff got airsick 5-10 minutes after take-off, so they had to land. DECEDENT asked Plaintiff to stay in his room when they got back to the hotel, but Plaintiffs mother said no. DECEDENT had also rented out an amusement park for everyone to visit. Plaintiff met Michael J. Fox at the convention, and for the entire time he was treated on a V.I.P. basis.
18. The Hawaii trip lasted a weekend. On the return flight to Los Angeles, California, Plaintiff conducted a “mock” interview of DECEDENT, using his cassette recorder. In that recorded interview, Plaintiff asked DECEDENT a series of questions, and DECEDENT provided responses, as follows:

Plaintiff: “What do you think about lying?”
DECEDENT: “People make up stories about [DECEDENT-referring to himself in the third person].”
Plaintiff: “Do you like performing?”
DECEDENT:. “Favorite things are writing songs, performing, and being with Jimmy [Plaintiff].”
Plaintiff: . “Any new plans?”
DECEDENT: “Smooth Criminal, short film, new Pepsi commercial, best Pepsi commercial was the one with Jimmy [Plaintiff] because he had ‘heart,’ best thing about Hawaii was spending time with Jimmy [Plaintiff], love [Plaintiffs] family and want to spend time with them.”

During this interview, DECEDENT. referred to Plaintiff by the nickname “Rubba.” This was a nickname that DECEDENT used to refer to Plaintiff early on in their relationship, and one that DECEDENT used to refer to other children, short for “rubber head”.
19. In 1988, Plaintiff first started dancing with DECEDENT. DECEDENT brought Plaintiff to his private dance studio and let Plaintiff watch him rehearse. DECEDENT told Plaintiff that he was the only person who was allowed to watch him rehearse. DECEDENT would rehearse 1/2 to 1 hour every Sunday- it was his ritual. If Plaintiff was around, he would be invited to attend the rehearsals to watch, and as time progressed, DECEDENT allowed Plaintiff to dance with him. Even though Plaintiff did not have formal dance training, DECEDENT would coach and teach him, and DECEDENT tQld Plaintiff that he had rhythm.
20. In 1988, DECEDENT began sleeping over at Plaintiffs family home. The first night that DECEDENT slept over, he stayed in Plaintiffs bedroom. DECEDENT ended up sleeping in Plaintiffs bedroom with him on a regular basis, which Plaintiffs parents knew. Plaintiff and DECEDENT would also sometimes pitch a tent in the living room and sleep in there. Plaintiff observed DECEDENT’s nightly regimen before going to sleep- taping his nose using white bandage tape, to form a shell to cover his nose. DECEDENT also used the empty bedroom of Plaintiffs older brother to meditate.

james-safechuck-43521. On March 11, 1988, Plaintiff and his mother accompanied DECEDENT as his guests to attend a performance of The Phantom of the Opera on Broadway, and both before and after the performance they all spent time together with Liza Minnelli. After the show, they all went backstage to meet the stars of the show, including Michael Crawford. Jolie Levine again made all the arrangements through MJJ PRODUCTIONS for them to fly to New York and DECEDENT and/or MJJ PRODUCTIONS paid for all of their expenses for the trip. Plaintiff and his mother stayed at the Trump Tower in Manhattan for the weekend. They went to FAO
Schwartz, the famous toy store, in addition to attending with him the performance of The Phantom of the Opera. Plaintiff stayed in his mother’s hotel room. Again DECEDENT asked for Plaintiff to stay in DECEDENT’s room with him, but Plaintiffs mother said no. But as soon as Plaintiff woke up in the morning, he would go to the DECEDENT’s room and stay there with him.
22. In or about 1988, DECEDENT invited Plaintiff to meet him in Pensacola, Florida, where DECEDENT and his band were rehearsing. DECEDENT and MJJ PRODUCTIONS
and/or MJJ VENTURES arranged for Plaintiff and his parents to travel to Florida, and stay in one of the houses that DECEDENT and MJJ PRODUCTIONS and/or MJJ VENTURES had rented there. Plaintiff stayed with DECEDENT in one house, and Plaintiffs parents stayed in one of the other houses. This was the first time that Plaintiff stayed with DECEDENT on a trip. DECEDENT also took Plaintiff and his parents for a side visit to Disney World.

Mj-safechuck23. The time that Plaintiff and DECEDENT spent together in 1988 increased significantly. DECEDENT encouraged Plaintiff to dress like him and grow his hair long like DECEDENT’s. DECEDENT had coaxed Plaintiff to become a “miniature version” of DECEDENT. Plaintiff did. DECEDENT gave Plaintiff many gifts of his clothing, some of which remain in Plaintiffs possession to this day. The “Thriller” jacket in which DECEDENT he had famously performed, was given previously to Plaintiff but DECEDENT later took it back. DECEDENT had become part of Plaintiffs family circle. However, DECEDENT never introduced Plaintiff or Plaintiff’s family to his own- Plaintiff saw Jermaine Jackson once at the Hayvenhurst house, and met Janet Jackson once when Plaintiff spent a weekend at Neverland when Janet Jackson and her husband, Renee; were also there.
24. In the early part of 1988, DECEDENT invited Plaintiff to join him on the “Bad” Tour. Plaintiff spent six (6) months·on the “Bad” Tour with DECEDENT, accompanied by his mother. Plaintiff joined DECEDENT for the second leg of the “Bad” Tour- in June (Europe) and stayed on the tour through December (where it concluded in Japan). During that 6 month period, Plaintiff returned to the U.S. to go back to school for several months. For the Japan portion of the tour, Plaintiff received course and homework from his school in Simi Valley so that he could keep up with his studies.
25. On the tour, Plaintiff performed nightly with DECEDENT on stage. He was not paid for his services, but DECEDENT and MJJ PRODUCTIONS organized and paid for all hotel and other accommodations; made and paid for all travel arrangements for Plaintiff and his mother (and also for Plaintiff’s father who joined the family for certain portions of the tour), and obtained multiple entry/exit visas to both France and Japan for Plaintiff; and paid for all food, entertainment and shopping sprees for Plaintiff and his parents. Jolie Levine was the point person for DECEDENT and MJJ PRODUCTIONS to make all the arrangements.
26. The first portion of the “Bad” Tour that Plaintiff attended was in Paris, France in approximately June 25-29, 1988. A replica of DECEDENT’s “Bad” Tour outfit was specially made by Michael Bush for Plaintiff to wear when he performed onstage with DECEDENT and for publicity events. During the “Bad” Tour, Plaintiff’s parents would go out to see tourist attractions- sometimes alone, and sometimes with other members of DECEDENT’s entourage and/or other employees of MJJ PRODUCTIONS and MJJ VENTURES. Plaintiff could not go, because if he went out in public, he would be hounded by the paparazzi and fans because of his
role on the tour with DECEDENT. No children participated on the “Bad” Tour other than Plaintiff.
27. The first incident of sexual abuse occurred during the Paris portion of the “Bad” Tour in June 25-29, 1988. At the time, DECEDENT was 29 years old and Plaintiff was 10 years old. DECEDENT [REDACTED] while DECEDENT and Plaintiff were together in DECEDENT’s room at the Hotel de Crillon in Paris. It was dark in the room. [REDACTED]
Later on, DECEDENT told Plaintiff when other sexual acts were involved, it was a way of “showing love.”
28. After the first incident of sexual abuse, Plaintiff began sleeping in DECEDENT’s room in bed with him on a regular basis during the rest of the “Bad” Tour.

article-2626762-1DC9A9D700000578-110_634x42529. On another occasion during the “Bad” Tour in 1988, [REDACTED]. DECEDENT referred to this activity as “selling me some,” because DECEDENT would give Plaintiff jewelry after he did this, as a “reward.” Plaintiff still has some of the jewelry DECEDENT gave to him after he abused him, which included a necklace with a medallion bearing DECEDENT’s face.
30. During the “Bad” Tour, DECEDENT taught Plaintiff code words to use so that other people would not know what they were talking about when they were referring to their sexual activities, including the phrase: “bright light, brick city” which referred to a “hard-on,” named for the motion picture Bright Lights, Big City. If Plaintiff and DECEDENT were holding hands, DECEDENT would also scratch the inside of Plaintiffs hand with one of his fingers—that was a sexual cue .
31. The “Bad” Tour ended in 1988 after Christmas in Japan. DECEDENT then flew Plaintiff to New York to spend time alone with him after DECEDENT performed at the Grammy’s in February 1989. Plaintiff travelled by himself. DECEDENT would occasionally arrange through MJJ PRODUCTIONS and MJJ VENTURES to have Plaintiff flown to see him at whatever location he was performing. During those visits, Plaintiff would sleep with DECEDENT in his hotel room, and ongoing sexual abuse would occur.

images32. From 1988 when the sexual abuse first began through 1992, DECEDENT engaged in ongoing sexual abuse of Plaintiff. DECEDENT would repeatedly instruct Plaintiff to be confident and to deny everything if ever asked about the abuse. DECEDENT told him to be quiet about it and not tell anyone, even his parents, about their relationship. DECEDENT told Plaintiff that he did not have to answer questions about what they did; that he should be vague and not give real answers to questions; and that if the police ever told Plaintiff that DECEDENT

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had “already confessed,” they were lying and trying to trick Plaintiff. DECEDENT would repeat over and over again to Plaintiff that their participation in sexual acts together was Plaintiff’s idea. He would drill that into Plaintiff over and over again throughout their relationship. DECEDENT would tell Plaintiff that it was okay to lie to other people, because nothing would happen if you lied.

33. DECEDENT frequently told Plaintiff that he would need to get married to protect his public perception. DECEDENT confessed to Plaintiff that his own father, Joseph Jackson, beat him when he was growing up if he “messed up” or did not rehearse, and that Plaintiff was now giving DECEDENT the childhood he never had.
34. By the time Plaintiff’s parents had a sex education discussion with him, he had already been abused by DECEDENT. Over time, the sexual abuse gradually escalated and became a “normal” part of the relationship Plaintiff had with DECEDENT. The sexual abuse continued in the same pattern of activity, with DECEDENT adding new components to the abuse including [REDACTED].
35. Plaintiff was confused about his sexuality, and wondered if he was gay. He did not think he was gay because he experienced feelings of having a “crush” on Sheryl Crow, who at the time was working as a back-up singer for DECEDENT. DECEDENT was jealous of Plaintiffs “crush” on Sheryl Crow, and told him that he should not like her. DECEDENT showed Plaintiff photographs of Sheryl Crow without her make-up on in an attempt to dissuade him from finding her attractive. DECEDENT was jealous of Plaintiffs attraction to females and any relationships with females that he had. DECEDENT consistently talked about women in a negative manner, and would point out to Plaintiff what he considered to be their physical flaws. DECEDENT told Plaintiff that women were smart, conniving and not to be trusted.

36. When DECEDENT purchased the Neverland Ranch in Santa Barbara County in 1988, Plaintiff was the first guest to stay overnight. At that time, there was no large “Neverland Ranch” sign, only the main house, pool and a trampoline. DECEDENT told Plaintiff when he bought it that it was Plaintiffs “home.” Whenever Plaintiff visited Neverland, he slept in DECEDENT’s bedroom. DECEDENT and Plaintiff would “mess up” the upstairs bedroom to make it look as though Plaintiff had slept there, when in actuality he stayed with DECEDENT in his bed.
37. DECEDENT eventually installed chimes in the hallway to his bedroom so that he could hear and be warned when people approached. DECEDENT later installed video cameras.
38. DECEDENT had a secret closet in his bedroom at Neverland which required a secret passcode to open. DECEDENT kept jewelry inside the closet, and would often abuse Plaintiff there. There was another closet on the other side of his bedroom which was larger, and DECEDENT would lay down a blanket in there so that there was more room to engage in sexual activities with Plaintiff. DECEDENT’s bedroom was located next to the library, and had a private bathroom to the right.
39. DECEDENT had the telephones at Neverland tapped so that he could listen to incoming and outgoing calls. On one occasion, DECEDENT had Plaintiff secretly listen in on a telephone call between Plaintiffs mother and aunt where Plaintiffs mother had said something negative about Plaintiffs father. After Plaintiff listened to the call, DECEDENT stated: “look how mean women are.”
40. DECEDENT also had all of the telephones in the guest houses at Neverland tapped. It was

common practice for DECEDENT and Plaintiff to listen in on telephone calls at Neverland.
41. On several occasions, Plaintiff took his best friend from school, Luke Martinez, to visit Neverland. During one of Luke’s visits; they had a slumber party and game-type activities. DECEDENT and Plaintiff would “sneak off’ to be alone and where sexual abuse would occur, but they were always careful to avoid getting caught. DECEDENT and Plaintiff were always careful when other people were around.
42. In a witness statement taken by the Santa Barbara County Sheriffs Department (“SBSD”) on September 22, 1993 in connection with the criminal investigation into the allegations of childhood sexual abuse made by Jordan Chandler against DECEDENT (SBSD Case No. 93-14563, the “Chandler Investigation”), [REDACTED] informed the SBSD that he had witnessed several incidences of suspicious activity between DECEDENT and Plaintiff at Neverland, including finding DECEDENT’s and Plaintiffs underwear lying next to DECEDENT’s bed, and seeing DECEDENT put his hand down the front of Plaintiffs shorts while the two were bathing together in a Jacuzzi. Mr. [REDACTED] informed the SBSD that there was gossip amongst the Neverland staff that DECEDENT was “having an affair” with Plaintiff and that they were sleeping together. Mr. [REDACTED] also stated that Norma Staikos (MJJ PRODUCTIONS’ Executive Director and head of operations at Neverland) told Mr. [REDACTED] and his wife never to leave children alone in a room with DECEDENT. (A true and correct copy of Mr. witness statement is marked as Exhibit A and contained in the separate Appendix filed herewith under seal)

43. In a witness statement taken by the SBSD on April 15, 1994 in connection with the Chandler Investigation, [REDACTED] stated that after Ms . Staikos took charge of operations at Neverland, she changed the security protocol with respect to DECEDENT’s arrival at the ranch gate in a vehicle. She said that under Ms. Staikos’ predecessor, the protocol was to stop DECEDENT at the gate and look inside his vehicle to ensure that DECEDENT had not been accosted or kidnapped and forced to drive to the ranch at gunpoint. However, after Ms. Staikos took over, security was told not to detain DECEDENT upon his arrival, and they would simply receive a phone call from Ms. Staikos telling them that DECEDENT was coming and who he was with, which was usually a juvenile boy. They would be given names such as “Jimmy” or “Wade.” Ms. [REDACTED] further stated that there were occasions when DECEDENT would enter. the ranch with a small boy and security would not be informed of the boy’s identity. On these occasions, Ms. Staikos would call security and tell them that DECEDENT was coming and that there was no reason to detain him. DECEDENT would then pass through the gate and drive up to the main house without stopping. When the identity of the boy accompanying DECEDENT was disclosed to security, they would greet DECEDENT and his guest upon arrival at the main house and help DECEDENT with his luggage. However, when DECEDENT would arrive unexpectedly with an unidentified boy, then the protocol would be for security to vacate the area around the main house so that they would not be physically close to DECEDENT or close enough to identify the boy. DECEDENT would generally arrive at night, between 10:00 p.m. and 2:00a.m. (A true and correct copy of Ms. [REDACTED] witness statement is marked as Exhibit B and contained in the separate Appendix filed herewith under seal)
44. Ms. [REDACTED] further stated that.on one occasion, DECEDENT arrived at the ranch gate while Ms. [REDACTED] was working there. As Ms. Staikos had not called to say that DECEDENT was arriving, Ms. [REDACTED] stopped his vehicle and approached the driver’s window. DECEDENT lowered the window just enough for Ms. [REDACTED] to see his eyes, and Ms. [REDACTED] also saw a young boy on the floor between the two front seats. As she looked at the boy, he moved behind the driver’s seat in an attempt to hide from her. DECEDENT told her to “make sure the front door is open.” Ms. [REDACTED] then called Ms. Staikos to inform her that DECEDENT had arrived, and Ms. Staikos “flew off the handle” when she heard that DECEDENT had arrived without her knowledge.
45. In a witness statement_taken by the SBSD on October 4, 1993 in connection with the Chandler Investigation, Blanca Francia, [REDACTED] informed the SBSD that Ms. Staikos “was the person who arranged things with the children and their families.” Ms. [REDACTED] stated that Ms. Staikos would arrange for a limousine to pick up Plaintiff and other children and take them to “The Hideout” to see DECEDENT. Ms. [REDACTED] said that Ms. Staikos “was in charge.” When Ms. Staikos began working for DECEDENT, she forced Ms. [REDACTED] to sign a confidentiality agreement. (A true and correct copy of Ms. [REDACTED] witness statement is marked as Exhibit C and contained in the separate Appendix filed herewith under seal).

images (1)46. In a witness statement taken by the SBSD on April 18, 1994 in connection with the Chandler Investigation, [REDACTED] informed the SBSD that she first heard about DECEDENT’s reputation regarding children soon after she began working for MJJ PRODUCTIONS in September 1989. Ms. [REDACTED] stated that while she was being given a tour of Neverland by Ms. Staikos, Ms. Staikos stopped near the door to DECEDENT’s room and told Ms. [REDACTED] “Never leave alone with Michael Jackson.” Ms. Staikos also told Ms. [REDACTED] that “That kid [DECEDENT] better be glad I understand his problem.” (A true and correct copy of Ms. [REDACTED] witness statement is marked as Exhibit D and contained in the separate Appendix filed herewith under seal).
47. Ms. [REDACTED] witness statement further confirms that Ms. Staikos exercised a significant degree of control over DECEDENT’s affairs in her capacity as the Executive Director of MJJ PRODUCTIONS. Ms. [REDACTED] stated that she was terminated by Ms. Staikos for appealing to DECEDENT regarding a request for a raise which Ms. Staikos had denied, and that DECEDENT later admitted to Ms. [REDACTED] that Ms. Staikos had forced DECEDENT to agree to the termination against his wishes.
48. In a witness statement taken by the SBSD on February 15, 1994 in connection with the Chandler Investigation, [REDACTED] further confirmed Ms. Staikos’ position of authority at Neverland and her control over DECEDENT’s affairs. Mr. [REDACTED] stated that Ms. Staikos would terminate any Neverland employee who got close to DECEDENT or anyone close to DECEDENT. (A true and correct copy of Mr. [REDACTED] witness statement is marked as Exhibit E and contained in the separate Appendix filed herewith under seal).
49. When Plaintiff was in the fourth grade, he had a “girlfriend.” When DECEDENT found out, he told Plaintiff that he could only have a relationship with him. DECEDENT called it a “faux committed relationship” that had to be kept secret.
50. DECEDENT would run “drills” regularly with Plaintiff and make Plaintiff practice putting on his clothes very fast and practice running away quietly so people would not hear him.
51. DECEDENT engaged in an ongoing campaign to instill fear in Plaintiff – he repeatedly told Plaintiff that if anyone found out about what they were doing, DECEDENT’s and Plaintiffs “futures would be over.” DECEDENT reminded Plaintiff of this on a constant basis.
52. DECEDENT was paranoid about what Plaintiff might tell other people. DECEDENT would constantly grill Plaintiff to tell him exactly what was said in conversations he had with other people. On one occasion, DECEDENT asked Plaintiff what was said in a conversation between Plaintiff and a female limousine driver that DECEDENT would regularly send to pick up Plaintiff for visits. When DECEDENT learned that she had asked him questions about DECEDENT, DECEDENT terminated her employment. After that, DECEDENT started driving over to Plaintiffs house himself to pick him up and bring him back for visits.

406d253cb59ca1738b98cd9dbdeac72b53. As time progressed, DECEDENT became more and more possessive of Plaintiff and escalated the nature of their relationship and the frequency of the sexual abuse. In addition to DECEDENT’s nickname for Plaintiff of “Rubba,” DECEDENT expanded their secret language and created sexual “codes.” DECEDENT referred to semen as “duck butter.” DECEDENT would scratch the inside of Plaintiffs palm as a sexual cue. DECEDENT performed a fake “marriage” with Plaintiff complete with a wedding ring and a signed document to pretend that they got married. DECEDENT would sometimes be a “jokester” with Plaintiff, saying that people were taking pictures of them while they were engaging in sexual activity, and had a light outside of his bedroom window at Neverland that he would flash to resemble a camera bulb flashing. DECEDENT also did that on the “Bad” Tour – he placed a small flashbulb on the other side of the hotel room curtain and made it flash. Plaintiff cried when he did that, and DECEDENT was surprised by his reaction.
54. DECEDENT trained Plaintiff to exchange declarations of love with him – it became a regular occurrence for them to say that they loved one another all of the time they were physically together, and over the many telephone calls they had. Once they became close, DECEDENT encouraged Plaintiff to stay away from an acting career and the spotlight. Plaintiff developed a significant emotional attachment to DECEDENT; DECEDENT always told Plaintiff that he would take care of him. Plaintiff began to wish that DECEDENT were his father.
55. DECEDENT engaged in sexual acts with Plaintiff hundreds of times – on tour, at Plaintiffs home, at DECEDENT’s apartment/condominium on Wilshire Boulevard in Westwood, at DECEDENT’s Century City condominium which was nicknamed “The Hideout,” and at Neverland.
56. In 1990-1991, Plaintiff spent time with DECEDENT at his apartment/condominium in Westwood and later at “The Hideout” in Century City, California. During this time frame, Plaintiff was 12-13 years old.
57. Plaintiff became a regular companion of DECEDENT. DECEDENT took Plaintiff on shopping excursions with him, including a shopping spree at The Sharper Image store in Studio City. DECEDENT frequently took Plaintiff shopping at stores on Ventura Boulevard and on Hollywood Boulevard, including a magic shop and costume store.
58. DECEDENT possessed many recording devices and high-tech briefcases equipped with recording devices. Plaintiff thought of them as high-tech “kids’ toys,” but DECEDENT used them in a manner that created a sense of paranoia of other people.

59. At or about the time Plaintiff turned 12, a transition period began where DECEDENT began to focus his attention on a younger boy, Brett Barnes (“Brett”). Get-togethers at The Hideout became more frequent, with other young boys that DECEDENT had invited in attendance. When DECEDENT was alone with Plaintiff at The Hideout, DECEDENT served Plaintiff pink wine, which was sweet, and together they would watch porn films. Some of the porn films were heterosexual in nature as were the pornographic books that DECEDENT showed to Plaintiff. Plaintiff was told by DECEDENT that these books were “foreign” books. DECEDENT also showed Plaintiff movies in which children were masturbating, and told him that they were “not really porn.” The movies that DECEDENT referred to as “porn” involved
adult sexual activities, whereas the films where children engaged in sexual activities were “not porn”.
60. When Plaintiff started puberty. at age 12, DECEDENT began to prepare Plaintiff for separation – telling him that he would “have other friends.” Plaintiff was upset hearing this and tried to preserve his relationship with DECEDENT by being extra nice and trying to befriend Brett Barnes, a younger boy with whom DECEDENT began to spend more time. Plaintiff became inwardly jealous of Brett because of the time and attention DECEDENT began devoting to him instead of Plaintiff.
61. On one of the weekends that Plaintiff spent with Brett and DECEDENT at The Hideout, Plaintiff began to feel as though he “was on the outs” with DECEDENT. The DECEDENT had spent the night in his bedroom with Brett, instead of with Plaintiff, and Plaintiff spent the night on the couch. Plaintiff experienced feelings of jealously as a result of being replaced by Brett.
62. As Plaintiff neared puberty, DECEDENT started grooming him for separation. This grooming period spanned several months. DECEDENT told the Plaintiff that he would be “seeing [the DECEDENT] with other people” but that they would continue on together “later on.” When Plaintiff fully reached puberty, DECEDENT began spending his time with Brett instead of with Plaintiff, and DECEDENT’s sexual abuse of Plaintiff finally stopped.
63. Once he reached puberty, and the sexual abuse stopped, Plaintiff would speak to DECEDENT less frequently. DECEDENT remained active in his life, however, and paid for the Plaintiff to direct several movies in high school. DECEDENT turned Plaintiffs focus away from scholastics and towards becoming a director. DECEDENT hired a professor from NYU to teach Plaintiff on the weekends how to direct films. DECEDENT told Plaintiff that “one day, we’re going to make movies together.” He also told Plaintiff to “study hard and be extraordinary” and that “[the DECEDENT] will be there to get [the Plaintiff’s] foot in the door” of the entertainment industry and motion picture business. DECEDENT and/or MJJ PRODUCTIONS and MJJ VENTURES arranged and paid for John Lugar to spearhead Plaintiff’s filmmaking and planning; hired Gretchen Sommerfeld to teach directing to Plaintiff; and also hired Craig Thorton to teach script writing to Plaintiff. DECEDENT arranged for Ms. Sommerfeld and Mr. Thorton to go to Plaintiff’s house on weekends to teach him about the filmmaking process.
64. DECEDENT told Plaintiff’s parents that he did not need to go to college, and convinced them to remove Plaintiff from his Advanced Placement (“AP”) courses. At the time, Plaintiff was very knowledgeable and skilled in mathematics. Nevertheless, he was taken out of his AP classes, and instead re-focused on directing by DECEDENT. Because Plaintiff’s own parents had not attended college, they were ill-equipped to guide their son in his scholastic endeavors, and were persuaded by DECEDENT to steer Plaintiff away from school and into directing.
65. In conversations with the DECEDENT about dropping AP classes, Plaintiff’s mother stated that her son would end up doing what the DECEDENT was doing in his career, to which DECEDENT agreed, stating that day would come, and when Plaintiff became a filmmaker, there would be “a line around the block” to see him. DECEDENT told Plaintiff to de-prioritize school, focus on movie-making, and not to worry because DECEDENT could get Plaintiff into college if he still wanted to go.
66. In 1992-1993, the DECEDENT and MJJ PRODUCTIONS arranged for the Plaintiff, and Plaintiff and his parents to take several trips. In 1992, Plaintiff and his parents went to Boston to attend a Deepak Chopra meditation retreat. Plaintiff and his family used the cover name “Andrews” when travelling to protect their identities from the media. In 1993, Plaintiff went alone to Washington, D.C. and DECEDENT arranged for the Plaintiff to visit the White House. Then, on the second leg of that trip to Chicago, when DECEDENT was doing the “Jam” video shoot, other boys were there, including Brett Barnes and also Wade Robson, who Plaintiff met for the first time. Plaintiff was sent home early from the trip, but Brett was allowed to stay. Brett slept with DECEDENT in his hotel room, and Plaintiff was upset about it and cried. DECEDENT saw Plaintiff crying, and within one to two days afterwards, Plaintiff was told by Bill Bray, DECEDENT’s longtime head of security/body guard, that he was going to be sent home, and that next day Plaintiff was on an airplane returning to California several days earlier than his scheduled departure.
67. In 1993, Plaintiff provided a witness statement to the police in connection with the criminal investigation of Jordan Chandler’s allegations against DECEDENT. DECEDENT told Plaintiff and his parents that the claims were complete extortion on the part of the Chandler family. Plaintiffs parents believed DECEDENT, and were convinced that he could do no wrong. Plaintiff met with one of DECEDENT’s lawyers at his office and rehearsed questions and testimony with him.

68. In 1994, Plaintiff worked as an intern/shadow director in Budapest, Hungary for DECEDENT’s “HIStory” promo video. Again, Plaintiff travelled and worked under the cover name “Jimmy Andrews” to protect his identity. Plaintiff appeared as “Jimmy Andrews” on the call sheets for the “HIStory” promo video and was employed as a production assistant. Plaintiffs mother accompanied him on the trip to Budapest, which lasted one-two weeks. DECEDENT and MJJ PRODUCTIONS arranged and paid for the travel and accommodations.
69. In 1995, Plaintiff was employed by the DECEDENT and/or MJJ PRODUCTIONS and MJJ VENTURES as an intern/shadow director for DECEDENT’s “Earthsong” video. Again, Plaintiff appeared on the call sheets for this video, which was filmed in New Jersey. Plaintiff was a wardrobe double on this shoot, and also appears as a hand double in the video for DECEDENT.
70. In late-1995 – early-1996, Plaintiff was again employed by MJJ PRODUCTIONS as a director for a short 35mm film, which was shot at Neverland. Plaintiffs employment on this shoot is reflected in a memorandum from the producer John Lugar to Evvy Tavasci at MJJ PRODUCTIONS.
71. In the years following 1995, after Plaintiff reached the age of 17, his relationship with DECEDENT tapered off. In 1997, Plaintiff enrolled in Moorpark Community College in an attempt to get good enough grades to enable him to seek admission to USC. That never came to fruition. Plaintiff never got the university education that he wanted; instead, his education had been derailed by DECEDENT’s persuasion of him and his parents that college was a waste of
time and that Plaintiffs future was in film direction.
72. During the time that Plaintiff was attending Moorpark Community College, he began having panic attacks. One occurred during a Spanish tutoring session. Plaintiff had no idea what was wrong with him. To stabilize his panic, he would excuse himself from wherever he was when he began to experience the attacks, and walk around until he could calm down enough to rejoin whatever he had been doing.
73. In 2005, DECEDENT contacted Plaintiff, and asked him to testify on his behalf in the criminal trial against DECEDENT in Santa Barbara for criminal sexual abuse. Plaintiff was approximately 27 years old at the time. DECEDENT started out the telephone call by saying that he wanted to help Plaintiff with his music and directing. He then asked Plaintiff to testify at trial on his behalf. When Plaintiff said no to the request, DECEDENT got angry and threatened him. Plaintiff told DECEDENT never to call him again, and that he wanted a normal life. DECEDENT got very angry and continued to threaten Plaintiff, telling him that he had the best lawyers in the world and that they would get Plaintiff for perjury from the 1993 Chandler investigation. Plaintiff had never experienced DECEDENT being so angry. Plaintiff was also panicked about DECEDENT talking to his mother—fearful that she would find out about his abuse by DECEDENT and be threatened by DECEDENT’s lawyers.
74. A few days after this telephone conversation, DECEDENT called Plaintiffs mother to try to get her to convince Plaintiff to testify on his behalf at the criminal trial. DECEDENT also wanted both of Plaintiffs parents to testify on his behalf. One to two days prior to DECEDENT’s call to his mother, Plaintiff had told his mother about the call he had received from DECEDENT and that he had declined to testify at the criminal trial. Plaintiff talked to her about the call and told his mother that DECEDENT was a “bad man,” but was unable to tell her any details or say anything but the very briefest statement that he had been abused. Plaintiff told his mother not to let DECEDENT know that she had found out. Plaintiff was panicked that DECEDENT would find out that he had told his mother. When DECEDENT called Plaintiffs mother, she pretended that she was not aware of DECEDENT’s earlier threatening call to her son, or about the abuse.
75. DECEDENT’s lawyers, together with Evvy Tavasci, DECEDENT’s executive personal secretary and an employee of MJJ PRODUCTIONS, contacted Plaintiff and told him that he needed to testify and deny anything that the cooks at Neverland said that they saw happen between Plaintiff and DECEDENT. Plaintiff told them that he did not want any further involvement with DECEDENT.
76. After the call with DECEDENT’s lawyers and Ms. Tavasci, DECEDENT called Plaintiff again. This call was towards the end of the criminal trial. DECEDENT told Plaintiff that that he “was sorry for not being there for [the Plaintiff].” The words that DECEDENT used and the tone of his voice appeared to Plaintiff to be rehearsed, as if the call were being tape recorded. Plaintiff feared that this was a possibility, as he knew from the past that DECEDENT often taped telephone calls on a regular basis. Plaintiff wanted to get off the telephone call as quickly as possible, as the very sound of DECEDENT’s voice made him very uncomfortable and put him into a panic mode. DECEDENT continued to pressure Plaintiff to testify and told him that Gavin Arviso (the victim in the criminal prosecution) was just trying to get money. Plaintiff told DECEDENT not to call or try to talk to him ever again, and then ended the call.
77. On June 25, 2009, DECEDENT died.
78. Upon learning of his death, Plaintiff felt sad because he realized he would never have the opportunity for a normal relationship with DECEDENT, and that his experiences with DECEDENT would never be resolved.
79. After the birth of his son, in late 2010, Plaintiff began to worry that he himself would have pedophilic urges. Plaintiff started to see how innocent children really were. Plaintiff had married a woman he worked with in 2007. He had never told her about his sexual abuse. During his wife’s pregnancy, Plaintiff had sought help from Dr. [REDACTED], a general practitioner, who prescribed Xanax to help with his anxiety. Plaintiff did not discuss the abuse with Dr. [REDACTED], nor did he equate his anxiety with the abuse. Plaintiff had coped with the abuse for many years by compartmentalizing what had happened during his relationship with DECEDENT.
80. Shortly after May 1, 2013, Plaintiff saw on the news that Wade Robson (“Wade”), who he had met in 1993, had filed a lawsuit against DECEDENT for claims of childhood sexual abuse. After learning that Wade had made public the sexual abuse that he had suffered at the hands of DECEDENT, Plaintiffs feelings of panic and anxiety heightened, and he thought that he might need help. By this time, Plaintiff now also had a newborn baby daughter, and his fears increased about his own children and what could happen to them.
81. Plaintiff never thought the feelings of panic and anxiety he had been suffering were the result of the sexual abuse by DECEDENT. Rather, he thought they were just a part of who he was. He had spent his entire life holding on to DECEDENT’s words that talking about what happened between them “would wreck [their] lives.”
82. Plaintiff first met with a psychiatrist, Dr. [REDACTED], on May 20,2013. He was finally able to discuss the abuse during his treatment. Plaintiff has been diagnosed with [REDACTED]. He is going to therapy one a week. Plaintiff tries to appear that he has “it together”, but struggles on a daily basis with his panic, depression and anxiety. He did not realize how “sick” it was that DECEDENT did the things he did to him as a child until he began therapy. Until he had his own children and realized how innocent they were and what “blank slates” they were, he did not appreciate that when you are made to think as a child that something was “your idea” it did not seem as bad as it actually was, as in the case of his abuse by DECEDENT.

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PENAL CODE AND CIVIL CODE VIOLATIONS OF DECEDENT

83. As used in CCP § 340.1, “childhood sexual abuse” includes “any act committed against the plaintiff that occurred when the plaintiff was under the age of 18 years and that would have been proscribed by Section 266j of the California Penal Code (“Penal Code”); Section 285 of the Penal Code; paragraph (1) or (2) of subdivision (b), or of subdivision (c), of Section 286 of the Penal Code; subdivision (a) or (b) of Section 288 of the Penal Code; paragraph (1) or (2) of subdivision (b), or of subdivision (c), of Section 288a of the Penal Code; subdivision (h), (i), or (j) of Section 289 of the Penal Code; Section 647.6 of the Penal Code … ”
84. As set forth more fully above, DECEDENT intentionally committed the following act against Plaintiff that occurred when Plaintiff was ‘under the age of sixteen ( 16) and which would have been proscribed by [REDACTED].
85. On multiple occasions, as set forth more fully above, DECEDENT intentionally committed the following act against Plaintiff that occurred when Plaintiff was under the age of fourteen (14) and which would have been proscribed by [REDACTED].
86. On multiple occasions, as set forth more fully above, DECEDENT intentionally committed the following act against Plaintiff that occurred when Plaintiff was under the age of fourteen (14) and which would have been proscribed by [REDACTED].
87. On multiple occasions, as set forth more fully above, DECEDENT intentionally
committed the following act against Plaintiff that occurred when Plaintiff was under the age of eighteen ( 18) and which would have been proscribed by
88. On multiple occasions, as set forth more fully above, DECEDENT intentionally [REDACTED].
committed the following act against Plaintiff that occurred when Plaintiff was under the age of eighteen (18) and which would have been proscribed by
89. On multiple occasions, as set forth more fully above, DECEDENT intentionally [REDACTED].
committed the following act against Plaintiff that occurred when Plaintiff was under the age of eighteen (18) and which would have been proscribed by
90. On multiple occasions, as set forth more fully above, DECEDENT intentionally [REDACTED].
committed the following act against Plaintiff that occurred when Plaintiff was under the age of eighteen (18) and which would have been proscribed by
91. On multiple occasions, as set forth more fully above, DECEDENT intentionally [REDACTED].
committed the following act against Plaintiff that occurred when Plaintiff was under the age of fourteen (14) and which would have been proscribed by
92. On multiple occasions, as set forth more fully above, DECEDENT intentionally [REDACTED].
committed the following act against Plaintiff that occurred when Plaintiff was fourteen (14) years old or older, but under the age of eighteen ( 18), and which would have been proscribed by [REDACTED].
93. On multiple occasions, as set forth more fully above, DECEDENT, intentionally committed the following act against Plaintiff that occurred when Plaintiff was under the age of eighteen (18) and which would have been proscribed by [REDACTED].
94. On multiple occasions, as set forth more fully above, DECEDENT intentionally committed the following act against Plaintiff that occurred when Plaintiff was under the age of eighteen (18) and which would have been proscribed by [REDACTED].
95. On multiple occasions, as set forth more fully above, DECEDENT intentionally committed the following act against Plaintiff that occurred when Plaintiff was under the age of sixteen (16) and which would have been proscribed by [REDACTED].
96. On multiple occasions, as set forth more fully above, DECEDENT intentionally committed the following act against Plaintiff that occurred when Plaintiff was under the age of fourteen (14) and which would have been proscribed by [REDACTED].
97. On multiple occasions, as set forth more fully above, DECEDENT intentionally committed the following act against Plaintiff that occurred when Plaintiff was under the age of eighteen (18) and which would have been proscribed by [REDACTED].
98. On multiple occasions, as set forth more fully above, DECEDENT [REDACTED].
99. On multiple occasions, as set forth more fully above, DECEDENT [REDACTED].

LIABILITY OF MJJ PRODUCTIONS, MJJ VENTURES AND DOES 4 THROUGH 50

100. Plaintiff is informed and believes, and on that basis alleges, that at the time DECEDENT’s violations of the Penal Code and Civil Code alleged in paragraphs 84 through 99 were committed, Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, had actual knowledge of, or were otherwise on notice of, prior acts of childhood sexual abuse committed by DECEDENT, and despite such knowledge and/or notice, placed Plaintiff in DECEDENT’s custody and/or made Plaintiff available to DECEDENT and then failed to take reasonable steps or implement reasonable safeguards to protect Plaintiff from DECEDENT’s acts of abuse. Plaintiff is further informed and believes, and on that basis alleges, that these acts and/or omissions on the part of Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, were committed in spite of their ability to exercise control over the personal and business affairs of DECEDENT. Accordingly, Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, are liable for DECEDENT’s acts of childhood sexual abuse in that their wrongful, intentional and/or negligent acts were a legal cause of the childhood sexual abuse within the meaning of CCP §§ 34Q.1(a)(2), (3) and (b)(2). 101. Given the knowing failure of Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, to protect Plaintiff as alleged herein, pursuant to CCP § 340.1(b)(2), the statute of limitations applicable to Plaintiffs claims against Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, is that provided in CCP § 340.1 (a), “within three years of the date the plaintiff discovers or reasonably should have discovered that psychological injury or illness occurring after the age of majority was caused by the sexual abuse.”

DAMAGES

102. As a direct and proximate result of the wrongful, intentional and/or negligent acts of Defendants as alleged above, Plaintiffs inter-personal relationships and ability to work has been detrimentally affected.
103. As a direct and proximate result of the wrongful, intentional and/or negligent acts of Defendants as alleged above, Plaintiff has suffered and will continue to suffer (a) severe mental and emotional distress including, but not limited to, severe anxiety, stress, anger, fear, low self-esteem, shame, humiliation, depression and physical distress; (b) expenses for mental health professionals and other medical treatment; and (c) loss of past and future earnings and other economic benefits according to proof at the time of trial.
104. The conduct alleged above included intentional, outrageous, malicious, despicable and oppressive acts beyond the bounds of decent behavior, which were undertaken, wantonly, oppressively and with a conscious disregard for Plaintiffs rights as a child. Plaintiff is therefore entitled to an award of punitive damages in an amount sufficient to punish, deter and make an example of those Defendants engaging in such behavior according to proof at trial.

SECOND CAUSE OF ACTION
(Childhood Sexual Abuse- Negligence as to all Defendants)

105. Plaintiff repeats, re-alleges and incorporates herein by reference paragraphs 1 through 104, inclusive, as though fully set forth herein.
106. As more fully set forth above in paragraphs 9, 15, 21, 22, 25, 31, and 45, the conduct and actions of DECEDENT and Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, served to create an environment in which DECEDENT was afforded continuous access to Plaintiff over a period of approximately four (4) years. These actions include, but are not. limited to: arranging for Plaintiff to have dinner at DECEDENT’s home on Hayvenhurst Avenue; arranging and paying for Plaintiff to travel to Hawaii, New York and Florida to attend events with DECEDENT; arranging and paying for Plaintiff to go on tour
and perform with DECEDENT in Europe and Japan for a period of six months; and arranging for limousines to transport Plaintiff to DECEDENT’s “Hideout.”
107. As more fully set forth above in paragraphs 42 through 46, Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, were aware and/or on
notice of DECEDENT’s proclivities for engaging in sexual acts with young boys prior to the first occasion on which Plaintiff was placed in DECEDENT’s custody through the acts of Defendants in or about 1988. Accordingly, at the time DECEDENT and Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, performed the acts alleged herein, it was or should have been reasonably foreseeable to Defendants that by continuously exposing and making Plaintiff available to DECEDENT, Defendants were placing Plaintiff in grave risk of being sexually abused by DECEDENT. By knowingly subjecting Plaintiff to such foreseeable danger, and by subsequently assuming the position of Plaintiffs employer, Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, were duty-bound to take reasonable steps and implement reasonable safeguards to protect Plaintiff from DECEDENT. Furthermore, as alleged herein, Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, at all times exercised a sufficient degree of control over DECEDENT’s personal and business affairs to prevent the acts of abuse by keeping DECEDENT away from Plaintiff. However, Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50,
inclusive, failed to take any reasonable steps or implement any reasonable safeguards for Plaintiffs protection whatsoever, and continued to make Plaintiff accessible to DECEDENT for the purposes of sexual abuse for a period of approximately four ( 4) years.
108. As a direct and proximate result of the failure of Defendants’ MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, to protect Plaintiff from
the acts of childhood sexual abuse to which he was subjected by DECEDENT, Plaintiff has suffered and will continue to suffer (a) severe mental and emotional distress including, but not limited to, severe anxiety, stress, anger, fear, low self-esteem, shame, humiliation, depression and physical distress; (b) expenses for mental health professionals and other medical treatment; and (c) loss of past and future earnings and other economic benefits according to proof at the time of trial.
109. As the gravamen of Plaintiffs claims for negligence against Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, is childhood sexual abuse, and Plaintiff has fulfilled the requirements of CCP § 340.1 (b )(2) as set forth above in paragraphs 100 and 101, the statute of limitations applicable to these claims is that provided in CCP § 340.l(a), “within three years of the date the plaintiff discovers or reasonably should have discovered that psychological injury or illness occurring after the age of majority was caused by the sexual abuse.”

THIRD CAUSE OF ACTION
(Childhood Sexual Abuse- Negligent Infliction of Emotional Distress as to all Defendants)

110. Plaintiff repeats, re-alleges and incorporates herein by reference paragraphs 1 through 109, inclusive, as though fully set forth herein.
111. As set forth more fully above in paragraphs 9, 15, 21, 22, 25, 31, and 45, Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, continuously made Plaintiff available and accessible to DECEDENT over a period of approximately four (4) years despite their prior knowledge of DECEDENT’s proclivities for sexual acts with young boys, and failed in their concomitant duty to take reasonable steps and implement reasonable safeguards to protect Plaintiff from DECEDENT. Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, at all times knew or should have known that their negligent acts and/or omissions were substantially certain to lead to DECEDENT’s acts of childhood sexual abuse, thereby resulting in severe emotional distress to Plaintiff.
112. As a direct and proximate result of the failure of Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, to protect Plaintiff from the acts of childhood sexual abuse to which he was subjected by DECEDENT, Plaintiff has suffered and will continue to suffer (a) severe mental and emotional distress including, but not limited to, severe anxiety, stress, anger, fear, low self-esteem, shame, humiliation, depression and physical distress; (b) expenses for mental health professionals and other medical treatment; and (c) loss of past and future earnings and other economic benefits according to proof at the time of trial
113. As the gravamen of Plaintiffs claims for negligent infliction of emotional distress against Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, is childhood sexual abuse, and Plaintiff has fulfilled the requirements of CCP § 340.1 (b)(2) as set forth above in paragraphs 100 and 101, the statute of limitations applicable to these claims is that provided in CCP § 340.1(a), “within three years of the date the plaintiff discovers or reasonably should have discovered that psychological injury or illness occurring after the age of majority was caused by the sexual abuse.”

FOURTH CAUSE OF ACTION
(Childhood Sexual Abuse- Breach of Fiduciary Duty as to all Defendants)

114. Plaintiff repeats, re-alleges and incorporates herein by reference paragraphs 1 through 113, inclusive, as though fully set forth herein.
115. As set forth more fully above in paragraphs 9, 15, 21, 22, 25, 31, and 45, Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, in
concert with DECEDENT, recruited, enticed, and encouraged Plaintiff and Plaintiffs parents to give their trust and confidence to Defendants and DECEDENT so that Plaintiff could be taken from his parents’ care and supervision and placed under the care and supervision of Defendants and DECEDENT. In so doing, Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, entered into a fiduciary relationship with Plaintiff whereby Defendants owed Plaintiff an in loco parentis duty of care to take all reasonable steps and implement all reasonable safeguards to protect Plaintiff while he was in the custody of Defendants and/or DECEDENT.
116. Plaintiff and his parents agreed to place their trust and confidence in Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, in the expectation that Defendants would properly supervise Plaintiff, regulate his activities and behavior, and ensure his safety. Further, Plaintiff and his parents agreed to this because they believed in the integrity of Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, and therefore felt comfortable in entrusting the minor Plaintiff to the care and custody of Defendants.
117. As alleged herein, DECEDENT breached his duty to Plaintiff by repeatedly subjecting Plaintiff to acts of childhood sexual abuse. As further alleged herein, Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, breached this duty to Plaintiff by failing to take any reasonable steps or implement any reasonable safeguards to protect Plaintiff from DECEDENT, and by allowing Plaintiff to be sexually abused by DECEDENT on a regular basis for approximately four (4) years.
118. As a direct and proximate result of Defendants’ MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, breach of their fiduciary duty to Plaintiff, Plaintiff has suffered and will continue to suffer (a) severe mental and emotional distress including, but not limited to, severe anxiety, stress, anger, fear, low self-esteem, shame, humiliation, depression and physical distress; (b) expenses for mental health professionals and other medical treatment;
and (c) loss of past and future earnings and other economic benefits according to proof at the time of trial.
119. As the gravamen of Plaintiffs claims for breach of fiduciary duty against Defendants MJJ PRODUCTIONS, MJJ VENTURES and Does 4 through 50, inclusive, is
childhood sexual abuse, and Plaintiff has fulfilled the requirements of CCP § 340.1 (b )(2) as set forth above in paragraphs 100 and 101, the statute of limitations applicable to these claims is that provided in CCP § 340.l(a), “within three years of the date the plaintiff discovers or reasonably should have discovered that psychological injury or illness occurring after the age of majority was caused by the sexual abuse.”

PRAYER FOR RELIEF
Wherefore, Plaintiff prays for Judgment against Defendants as follows:
1. For compensatory damages according to proof;
2. For punitive damages according to proof;
3. For an award of interest, including prejudgment interest, at the legal rate;
4. For an award of attorneys’ fees, to the extent permitted by law;
5. For costs of suit incurred herein; and
6. For such other and further relief as the Court deems just and appropriate.