Case 2:15-cv-08130 Document 1 Filed 10/16/15 Page 1 of 31 Page ID #:1 1 Cindy Pánuco, Esq. [S.B. #266921] Brian Olney, Esq. [S.B. # 298089] 2 HADSELL STORMER & RENICK LLP 128 N. Fair Oaks Avenue 3 Pasadena, California 91103 4 Telephone: (626) 585-9600 Facsimile: (626) 577-7079 5 Emails:
[email protected] [email protected] 6 7 Attorneys for Plaintiffs 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 AHMET DOĞAN, individually and on Case No.: behalf of his deceased son FURKAN 11 COMPLAINT FOR DAMAGES: DOĞAN; and HIKMET DOĞAN, 12 individually and on behalf of her 1. Extrajudicial Killing in Violation of 13 deceased son, FURKAN DOĞAN, Torture Victim Protection Act, by Ahmet Doğan 14 2. Extrajudicial Killing in Violation of Plaintiffs, Torture Victim Protection Act, by 15 Hikmet Doğan vs. 3. Torture In Violation of Torture 16 Victim Protection Act, by Ahmet Doğan and Hikmet Doğan on Behalf 17 EHUD BARAK, of Furkan Doğan as his Successors in Interest 18 Defendant. 4. Extrajudicial Killing in Violation of 19 Alien Tort Claims Act, by Ahmet Doğan 20 5. Extrajudicial Killing in Violation of Alien Tort Claims Act, by Hikmet 21 Doğan 6. Acts of International Terrorism in 22 Violation of Anti-Terrorism Act, by Ahmet Doğan and Hikmet Doğan on 23 Behalf of Furkan Doğan as his Successors in Interest 24 7. Acts of International Terrorism in Violation of Anti-Terrorism Act, by 25 Ahmet Doğan 26 8. Acts Of International Terrorism In Violation Of Anti-Terrorism Act, by 27 Hikmet Doğan 28 DEMAND FOR JURY TRIAL COMPLAINT FOR DAMAGES Case 2:15-cv-08130 Document 1 Filed 10/16/15 Page 2 of 31 Page ID #:2 1 INTRODUCTION 2 1.