BC485779 S 3K 21 LEDDURE RASHAD BAUMAN and Case No 22 VERONICA BAUMAN, His Wife; JOHN W
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1 GIRARDI I KEESE FILED SUPERIORCOURTOFCAUFOR.NIA 2 THOMAS V. GIRARDI, Bar No. 36603 COUNTVOFL05A.NGELES 1126 Wilshire Boulevard 3 Los Angeles, California 90017 MAY 3 1 2012 Telephone: (213)977-0211 4 ;e.ExecutiveOflicer/Cleric Facsimile: (213)481-1554 ., Deputy 5 '»Wesley RUSSOMANNO & BORRELLO, P.A. 6 Herman Russomanno (FloridaBar No. 240346)Pro Hac Vice ApplicationForthcoming 7 Robert Borrello (Florida BarNo. 764485) Pro Hac Vice Appliication Forthcoming 150 West Flagler Street - PH 2800 8 Miami, FL 33130 9 Telephone: (305) 373-2101 Facsimile: (305) 373-2103 10 11 GOLDBERG, PERSKY & WHITE, P.C. Jason E. Luckasevic (Pennsylvania Bar No. 85557) Pro Hac Vic^ Application Forthcoming 12 1030 Fifth Avenue 13 Pittsburgh, PA 15219 Telephone: (412) 471-3980 14 Facsimile: (412) 471-8308 XI m 15 Attorneysfor Plaintiffs *3s ^ f> fj *> ?0£3E3>35?"5> {/} to *3s _ "» 16 J? S * O 17 ^ 0"> o oa 9« »-«•oS•*» cj53 SUPERIOR COURT OF THE STATE OF' CALIFORNIA to v*- O- *o »— ti fv) «o r- 18 o £5 m o CD ». COUNTY OF LOS ANGELES o o S ^ 19 ;• 01 m 20 a w BC485779 s 3K 21 LEDDURE RASHAD BAUMAN and Case No 22 VERONICA BAUMAN, his wife; JOHN W. BEASLEY and PATRICIA BEASLEY, his wife; 23 JEFF BLACKSHEAR; CARLTON BREWSTER; 2 jg*o trt a> 3> — • JOSEPH CAMPBELL; FRED H. COOK HI; COMPLAINT FOR DAMAGES 3? si 8! < 24 COREY V. CROOM; PATRICK CUNNINGHAM ro -k ^ *•* o> 3>- 3C ^- 3E «• fi? a» »- 25 and DEBBIE CUNNINGHAM, his wife; 20 2t> cn rn •» «* TIMOTHY DANIEL; ENNIS R. DAVIS, II; DEMAND FOR JURY IrI^ 2 <= 2 v> o* o oo • "v o en 26 MICHAEL DAVIS and GWENDOLYN DAVIS, o o ae -a O •-* -J* ^J his wife; KEVIN DEVINE; ARNOLD FIELDS ~v. Qs •« » 27 ^> r\> •« r- • Q X- and OLGA FIELDS, his wife; ROGER L. FINNIE o o o -^ o •<! ro o S •• * m i 28 rj ft o -1- ca o- o ae • COMPLAINT FOR DAMAGE!? and LAURIE F1NNIE, his wife; DARRELL FORD; LARRY FOSTER; DONALD FRANK; 2 DAVID GIBSON and JENNIFERGIBSON, his wife; ISAAC HAGINS; OTHELLO 3 HENDERSON, III; NATHANIEL HENSLEY and 4 AMBER HENSLEY, his wife; KENNETH HEROCK and ANTOINETTE HEROCK, his 5 wife; JESSIE LEE HESTER and GERLIENUS HESTER, his wife; DALLAS HICKMAN and 6 CELESTE HICKMAN, his wife; GAYLON 7 HYDER and MELINDA HYDER, his wife; EDDIE LEE IVERY and ANTOINETTE IVERY, 8 his wife; STEPHEN W. JACKSON; WILLIAM JACO and JOAN JACO, his wife; DIRK 9 JOHNSON and JENNIFER JOHNSON, his wife; JOHN KAISER and RESA KAISER, his wife; . 10 JAMES MARSHALL and SUSAN LANDWEHR 11 MARSHALL, his wife; COREY MAYFIELD and TONIA MAYFIELD, his wife; DAVID 12 MCMILLAN; ERIK NORGARD; MARVIN D. OWENS and ROMELL OWENS, his wife; 13 RICKY PARKER and JULIE PARKER, his wife; 14 MARION TODD PEAT and JANA PEAT, his wife; CHARLES PHARMS III; DAMON PIERI 15 and JENNIFER PIERI, his wife; JUAN A. ROQUE and JENNIFER ROQUE, his wife; 16 WILLIARD SCISSUM and ANDREUILLE 17 SCISSUM, his wife; JASON SHELLEY and JANINE SHELLEY, his wife; OMAR SMITH and 18 RACHEL SMITH, his wife; TRENT SMITH; ALPHONSO TAYLOR and HEATHER 19 TAYLOR, his wife; ANTHONY WALLACE and 20 KEISHA WALLACE, his wife; CHARLES WESLEY WALLS and CHRISTY WALLS, his 21 wife; DEREK WARE and VIVIAN WARE, his wife; TINA RICKS, Personal Representative ofthe 22 Estate ofANDRE M. WATERS, a/k/a ANDRE 23 MAURICE WATERS, Deceased, KENNY WATSON; JONATHAN WELLS; KENNETH 24 WHEATON and FRANCHELL WHEATON, his wife; JAMES DAVID WILKINS, II; DAVID 25 WILLIAMS; LESTER JOE WILLIAMS; 26 SIRMAWN WILSON and HEATHER WILSON, his wife; SCOTT ZIMMERMAN and LINDSEY ST 27 ZIMMERMAN; his wife; ERIC ZOMALT and CYNTHIA ZOMALT, his wife, 2* 28 COMPLAINT FOR DAMAGES: 1 Plaintiffs, 2 3 4 NATIONAL FOOTBALL LEAGUE; NFL PROPERTIES LLC; RIDDELL, INC. d/b/a 5 RIDDELL SPORTS GROUP, INC., ALL AMERICAN SPORTS CORPORATION, d/b/a 6 RIDDELL/ALL AMERICAN; RIDDELL SPORTS GROUP, INC., EASTON-BELL 7 SPORTS, INC.; EASTON-BELL SPORTS, LLC; 8 EB SPORTS CORP.; and RBG HOLDINGS CORP.; and JOHN DOES 1 through 100, 9 Inclusive, 10 Defendants. 11 12 The Plaintiffs, all individuals, hereby complain of Defendants listed above and hereby allege as 13 14 follows: 15 PARTIES 16 Plaintiffs: 17 1. Mr. Leddure Rashad Bauman and his wife, Veronic^i, are residents ofand domiciled in the 18 State ofOregon. 19 20 2. Mr. John W. Beasley and his wife, Patricia, are residents of and domiciled in the State of 21 Wisconsin. 22 3. Mr. Jeff Blackshear is a resident ofand domiciled in the State of Maryland. 23 4. Mr. Carlton Brewster is a resident ofand domiciled i^i the state of Michigan. 24 5. Mr. Joseph Campbell is a resident ofand domiciled m ithe State ofArizona. 25 26 6. Mr. Fred H. Cook III is a resident ofand domiciled m the State ofMississippi. & 27 7. Mr. Corey V. Croom isa resident of anddomiciled i|i the Stateof Ohio. ^ 28 -3- COMPLAINT FOR. DAMAGES 1 8. Mr. Patrick "Rick" Cunningham and his wife, Debbie, are residents of and domiciled in the 2 State of Arizona. 3 9. Mr. Timothy Daniel is a resident ofand domiciled in the State ofGeorgia, 4 10. Mr. Ennis R. Davis II is a resident ofand domiciled in the State ofCalifornia. 5 11. Mr. Michael Davis and his wife, Gwendolyn, are residents ofand domiciled in the State of 6 Pennsylvania. 7 8 12. Mr. Kevin Devine is a resident ofand domiciled in tHeState of California. 9 13. Mr. Arnold Fields and his wife, Olga, are residents of and domiciled in the State of 10 California. II 14. Mr. Roger L. Finnic and his wife, Laurie, are residents of and domiciled in the State of 12 Florida. 13 14 15. Mr. Darrell Ford is a resident ofand domiciled in the State ofConnecticut. 15 16. Mr. Larry Foster is a resident ofand domiciled in the State of Louisiana. 16 17. Mr. Donald Frank is a resident ofand domiciled in the State ofNorth Carolina. 17 18. Mr. David Gibson and his wife, Jennifer, are residents of and domiciled in the State o 18 Florida. 19 20 19. Mr. Isaac Hagins isa resident of and domiciled in the);State of Florida. 21 20. Mr. Othello Henderson, 111 is a resident ofand domiciled in the State ofTexas. 22 21. Mr. Nathaniel "Nate" Plensley and his wife, Amber,, are residents of and domiciled in the 23 State ofTexas. 24 22. Mr. Kenneth Herock and his wife, Antoinette, are residents of and domiciled in the State of ' 25 26 Georgia. ^ 27 // i -4- COMPLAINT FOR DAMAGES 1 23. Mr. Jessie Lee Hester and his wife, Gerlienus, are residents ofand domiciled in the State of 2 Florida. 3 24. Mr. Dallas Hickman and his wife, Celeste, are residents of and domiciled in the State of 4 Arizona. 5 25. Mr. Gaylon Hyder and his wife, Melinda, are residents of and domiciled in the State of 6 Texas. 7 8 26. Mr. Eddie Lee Ivery and his wife, Antoinette, are residents of and domiciled in the State of 9 Georgia. 10 27. Mr. Stephen W. Jackson is a resident ofand domiciled in the State ofVirginia, 11 28. Mr. William Jaeo and his wife, Joan, are residents ofand domiciled in the State ofTexas, 12 29. Mr. Dirk Johnson and his wife, Jennifer, are residents of and domiciled in the State of 13 14 Colorado. 15 30. Mr. John Kaiser and his wife, Resa, are residents ofaWl domiciled in the State ofArizona. 16 31. Mr. James Marshall and his wife, Susan, are residents of and domiciled in the State of 17 Minnesota. 18 32. Mr. Corey Mayfieid and his wife, Tonia, are residents of and domiciled in the State of 19 20 Texas. 21 33. Mr. David McMillan is a resident ofand domiciled in the State ofGeorgia. 22 34. Mr. Erik Norgard is a resident ofand domiciled in th^ State ofColorado. 23 35. Mr. Marvin D. Owens and his wife, Romell, are residents of and domiciled in the State of 24 California. 25 26 36. Mr. Ricky Parker and his wife, Julie, are residents ofand domiciled in the State ofArizona » 27 * // S28 COMPLAINT FOR DAMAGES 1 37. Mr. Marion Todd Peat and his wife, Jana, are residents of and domiciled in the State of 2 Arizona. 3 38. Mr. Charles Pharms III is a resident ofand domiciled in the State ofTexas 4 39. Mr. Damon Pieri and his wife, Jennifer, are residents of and domiciled in the State of 5 Arizona. 6 40. Mr. Juan A. Rpque and his wife, Jennifer, are residents of and domiciled in the State of 7 8 Arizona. 9 41. Mr. Willard Scissum and his wife, Andreuille, are residents of and domiciled in the State of 10 Georgia. 11 42. Mr. Jason Shelley and his wife, Janine, are residents ofand domiciled in the State ofTexas, 12 43. Mr. Omar Smith and his wife, Rachel, are residents ofand domiciled in the State of Florida. 13 14 44. Mr. Trent Smith is a resident ofand domiciled in the State ofOklahoma, 15 45. Mr. Alphonso Taylor and his wife, Heather, are residents of and domiciled in the State of 16 Arizona. 17 46. Mr. Anthony Wallace and his wife, Keisha, are residents of and domiciled in the State of 18 California. 19 20 47. Mr. Charles Wesley Walls and his wife, Christy, art residents of anddomiciled in the State 21 ofNorth Carolina. 22 48. Mr. Derek Ware and his wife, Vivian, are residents ofand domiciled in the State of Arizona, 23 49. Ms. Tina Ricks, Personal Representative of the E;3tate of Andre M.