veanaeoatee MANLY, STEWART & NALD! aoivoe ewes, sore 88 hone ronan 40 n 12 3 4 15 16 W 18 19 20 a 2. 23 24 25 26 an 28 my JOHN C. MANLY, Esq, (State Bar No, 149080) ollie RUSE FINALI Guat Bae No. 238279) 7 Ate, ALEX CUNNY (State Bar No. 291567) MANLY, STEWART & FINALDI SEP 19 2016 19100 Von Karman Ave, Suite 800 Sheri R, Rie Gy zn00 yam a one: - Fano) 252.9991 By Donte Foves Dopiy ** ‘Attomeys for Plaintiff JAMES SAPECHUCK SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT JAMES SAFECHUCK, an individual, Case No.: BCS45264 ‘ [Related to civil case, BC508502, Wade Robson Plaintiff, ¥. MIJ Productions, et al, and probate case a BPLI7321, In re Estate of Michael Joseph : Jackson] ‘MJJ PRODUCTIONS, INC, a California [Both cases assigned to the Honorable Judge tion; MJJ VENTURES, INC. a ‘Mitchell L. Beckloff, Dept. 51] ja corporation; and DUES 6-50, SECOND AMENDED COMPLAINT FOR DAMAGES FOR: (1) INTENTIONAL INELICTION OF EMOTIONAL DISTRESS; ) NEGLIGENCE} NEGLIGENT SUPERVISION; (@) NEGLIGENT RETENTION/EURING; (6) NEGLIGENT FAILURE TO WARN, ‘TRAIN OR EDUCATE; and (© BREACH OF FIDUCIARY DUTY. [illed pursuant fo C.CP. § 340.1] DEMAND FOR JURY TRIAL Complaint Filed: May 9, 2014 ‘rial Date: None Set Defendants.“ered Ven Kannan, Sure 000 trate, Garon 2612 MANLY, STEWART 8 FINALDI aauerun 10 u 12 13 14 15 16 7 18 19 20 24 22 23 24 25 26 20 28 Plaintiff JAMES SAFECHUCK (‘Plaintiff’) hereby alleges against Defendants MII PRODUCTIONS, INC., MIS VENTURES, INC. and Does 6 through 50, inclusive (“Defendants”) as follows: PARTIES 1. Plaintiff'is a male individual and resident of the County of Los Angeles, State of California, He brings this action pursuant to C.C.P. section 340.1 for the childhood sexual abuse he suffered at the hands of Michael Joseph Jackson, MJJ PRODUCTIONS, INC., and MIJ VENTURES, INC. 2, Michae] Jackson (hereinafter “MICHAEL JACKSON”) 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, MICHAEL JACKSON 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 MICHAEL JACKSON died in Los Angeles, California on Kune 25, 2009, at the age of fifty (50). 3. Plaintiff is informed and believes, and thereupon alleges, that Defendant MJ PRODUCTIONS, INC. (“MJT PRODUCTIONS”) is a California corporation, with a principal place of business located in the County of Los Angeles, State of California, Plaintiff's further informed and believes, and thereupon alleges, that at all times relevant herein, MII PRODUCTIONS was a company established by MICHAEL JACKSON es his primary business entity and the entity that held most or all of the copyrights to MICHAEL JACKSON’s music and videos. Plaintiff is further informed and believes, and thereon alleges, that MICHAEL JACKSON was the president/owner and a representative/agent of MIJ PRODUCTIONS at all times relevant herein, and that in that capacity, MJJ PRODUCTIONS had the ability to exercise control over MICHAEL JACKSON’s business and personal affairs. Plaintiff is farther informed and believes, and thereon alleges, that MICHAEL JACKSON, 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 Mt 1 ‘SECOND AMENDED COMPLAINTMANLY, STEWART FINALO! "oreo ven RanunAve 9076200 25 26 27 28 MICHABL JACKSON and the minor Plaintiff and other children for the purpose of MICHAEL JACKSON’s engaging in childhood sexual abuse of Plaintitf and others. 4, Plaintiffis informed and believes, and thereupon alleges, that Defendant MJJ ‘VENTURES, INC. (“MIJ 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, MJ VENTURES was & company established by MICHAEL JACKSON in part for the purpose of employing Plaintiff to work with MICHAEL JACKSON on various projects, and further, that MICHAEL JACKSON ‘was the president/owner and a representative/agent of MJJ VENTURES at all times relevant herein, and that in that capacity, MIJ VENTURES had the ability to exercise control over MICHAEL JACKSON’s personal and business affairs. Plaintiff is further informed and believes, and thereon alleges, that MICHAEL JACKSON, with MIJ 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 MICHAEL JACKSON and Plaintiff for the purpose of MICHAEL JACKSON engaging in childhood sexual abuse of Plaintiff 5. Inperforming the acts complained of herein, MICHAEL JACKSON acted with the fall 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. MJJ PRODUCTIONS and MJ} VENTURES were held out to the public to be businesses dedicated to creating and distributing multimedia entertainment by MICHAEL JACKSON, however, in fact, they actually served dual purposes. The thinly-veiled, covert second purpose of these businesses was to operate as a child sexual abuse operation, specifically designed to locate, attract, lure and seduce child sexual abuse vis tims. Jn fact, under this dual purpose, MICHAEL JACKSON and select few managing agents/employees of MIT PRODUCTIONS’s and M3J VENTURES’ inner circle designed, developed and operated what is likely the most sophisticated public child sexual abuse procurement and facilitation organization the world hes known. As a result thereof, Defendants MIJ PRODUCTIONS and MIT VENTURES are liable for MICHABL JACKSON's acts of childhood sexual abuse within the 2 SECOND AMENDED COMPLAINT