Case 2:20-cv-09582-JFW-E Document 54 Filed 03/17/21 Page 2 of 41 Page ID #:1137
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Plaintiff Vanessa Bryant (“Plaintiff”), by way of her undersigned counsel, hereby brings this motion towards defendants County of Los Angeles (the “County”), the Los Angeles County Sheriff’s Department (the “Sheriff’s Department”), the Los Angeles County Fire Department (the “Fire Department,” and, collectively with the County and the Sheriff’s Department, the “Entity Defendants”), Joey Cruz, Rafael Mejia, Michael Russell, and Raul Versales (collectively, the “Deputy Defendants,” and, collectively with the County, the Sheriff’s Department, and the Fire Department, the “Defendants”) searching for damages to treatment violations of rights below the United States Constitution and for negligence and invasion of privateness pursuant to California regulation. This Court has material jurisdiction pursuant to twenty-eight U.S.C. sections 1331 and 1343. Plaintiff alleges, on private information as to herself and data and perception as to others, as follows: INTRODUCTION 1. On the morning of Sunday, January 26, 2020, three eighth-grade ladies, joined by dad and mom and coaches, left their houses in Orange County to play in a youth basketball event in Thousand Oaks. Making their means by helicopter, they encountered dense fog. Rather than land or flip round, the pilot pushed into the fog and have become disoriented. The helicopter descended quickly and crashed into the foothills of the Santa Monica Mountains, killing everybody onboard. Vanessa Bryant’s 13 yr-previous daughter, Gianna Bryant, and husband of almost twenty years, Kobe Bryant, had been amongst those that died. 2. In the aftermath of the crash, a number of of the victims’ members of the family gathered on the L.A. County Sheriff’s station in Lost Hills, devastated and distraught. Sheriff Alex Villanueva met with them and guaranteed Mrs. Bryant that his deputies had been securing the crash website. Based on a leak by regulation enforcement, the gossip and movie star information website TMZ had reported that Kobe, a singular determine in
Case No. 2:20-cv-09582-JFW-E FIRST AMENDED COMPLAINT
