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
c
Q
Babak Pourtavoosi, Esquire, SBN 216287
Law Offices of Babak Pourtavoosi PC
Of counsel to Pannun The Firm, PC
75-20 Astoria Boulevard, Suite 170
Jackson Heights, NY 11370
(718) 672-8000; Fax: (718) 732-4514
Bpesq2@yahoo.com
Attorney for Plaintiffs
Q ORIGINAL
UNITED STATES
CENTRAL DISTRIC
DISTRICT COURT
OF CALIFORNIA
o
or
""
o-t-H
m' xj
-rljO
o
CD
CO
11
r
m
o
SIKHS FOR JUSTICE, INC. "SFJ"
On behalf of deceased and injured
Member of Sikhs community;
BABU SINGH DUKHIYA, on his own
behalfand on behalf of deceased and injured'
Family members; and
MOHINDER SINGH, on his own behalf
And on behalf of deceased and
Injured family members
Plaintiffs,
CVU-08297M&}
Civ No
AMITABH BACHCHAN,
a national and citizen of India
Defendant.
Complaint
SFJ, et al. v. Amitabh Bachchan
- 1
COMPLAINT
A CIVIL ACTION
CLASS ACTION
JURY TRIAL DEMANDED
F,\iJ
OCT l T ?n!A
Cle- '.!S D;sirictCout
COURT 4612
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
o
O
1. Plaintiffs, on behalf ofthemselves, tieir deceased family members and all
others similarly situated who were victims of or related to the victims of
"Sikh Genocide of November 1984'
hereinafter referred to as "The Sikh
Genocide of 1984" which is popular
Sikh Riots of 1984" (collectively "Plaintiffs"), as and for their complaint
against the Defendant inthis action respectfully allege as follows
I. PRELIMINARY STATEMENT
2. In the year 2013, the Defendant possessed a major role in a famous
y and purposely misnomered as "Anti
Americanmovie "The Great Gatsby'
Hollywood film industry located witjiin
made, sponsored and released by the
in the territorial jurisdiction of this
court. The movie which won 2 Oscar awards was co-starred by Leonardo
DiCaprio and was produced by Warner Bros.
3. On October 31, 1984 after Indira Gandhi the then Prime Minister of India
and head of ruling Congress party was declared dead at All India Institute of
Medical Sciences (AIIMS), the Defendant Amitabh Bachchan, raised the
slogans "Sikho ne Indira Ji ko mar dal
la" ("Sikhs have killed Indira");
ko" ("Kill these bastards , they are
traitors"); 'khoon ke cheentay Sikhoi|i ke ghar ghar tak puhnchanay
'Maro Saalon ko, desh ke ghaddaron
chahiyay'" ("the blood stains should reach the households of Sikhs") and
Complaint
SFJ, et al. v. Amitabh Bachchan
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
Q
o
"khoon ka badla khoon" ("blood for
blood"). Hearing defendant Bachchan's
call for violence against Sikhs, otherwise shocked and numb crowd
immediately reacted violently towards Sikhs present in the crowd and started
beating them.
4. "Blood for blood" slogan raised byEachchan turned into "Ebola Virus" as it
was instantly pickedby the crowd and India's state owned TVStation "Door
Darshan" and All India Radio started telecasting slogans of "Blood for
Blood" resulting in the killing of moi[e than 30,000 Sikhs across the country
during the next few days.
5. Telecast of slogans by the state owned
media callingfor violence against
for Democratic Rights (PUDR) and
Sikhs was reported by People's Union
People's Union for Civil Liberties (PUCL) intheir report "Who Are the
Guilty" stating that "[w]e were also intri
iguedto find Doordarshan (the State-
allowing the broadcast of highly
khoon' (blood for blood)."1
controlled Indiantelevisionnetwork)
provocative slogans like 'khoon ka badla
1"Who Are The Guilty" AReport of ajoint
the riots in Delhi from 31 October to 10November
finding team jointlyorganised [sic] byone
(PUDR) and people's Union for Civil Liberties
investigations from November 1to November
the attacks on members of the Sikh
period, far from being a spontaneous
Complaint
SFJ, et al. v. Amitabh Bachchan
-3
inquiry into the causes andimpact of
1984 PUCL - PUDR A fact-
people's Union for Democratic Rights
(PUCL) in the course of
10, has come to the conclusion that
Community in Delhi and its suburbs during the
expression of"madness" and of popular
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
Q
Q
6. The slogans calling for blood of Sikhs coined and raised by defendant
Bachchan a day earlier outside AIIMS instantly became so popular that they
were also raised by the crowed at Teen Murti on November 1during Indira
Gandhi's burial.
7. Defendant Amitabh Bachchanwas considered by many in Indiato be an
iconic legenddue to his movie star roles in Bollywood and also known for
his personal appearances on the government-owned All-India radio and
television networks. He was generally liked and well known in such
capacities during the 1980's. When he spoke, his words were like a plagued
virus spreadingwildly without end aid the people listened and moved at his
beckon call. That notoriety and fame
was used in what has become known
as "The Sikh Genocide of 1984" foil :>wing the assassination of Prime
Minister Indira Ghandi, a woman who Defendant revered as a "mother
figure" and with whomhe had close :ies to her family, to excercise,
facilitate, and proliferate the murders
"grief and anger" at Mrs. Gandhi's assassination
authorities, were the outcome of a well org
deliberate commissions and omissions by
at the top and by authorities in the administ
http://www.pucl.org/Topics/Religion-comnliunalism/2003/who
2See "Who Are the Guilty" at ibid.
Complaint
SFJ, et al. v. Amitabh Bachchan
of countless thousands. Since then to
as made out to be by the
inised [sic] plan marked by acts of both
important politicians of the Congress (I)
ation.
are-guilty.htm.
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
o
Q
the Sikh community, Defendant Amitabh Bachchan became known as the
"butcher" because his words had lee
members of a primarily peaceful rel
to the slaughter of over 30,000
gion, Sikhism. Defendant's words and
anti-Sikh propaganda were like venom being spit out of acobra poisoning
the minds andhearts of all they touched
8. Reach, magnitude and consequences
Sikhs was aptly reported by Hindustan
showing 16 states of India where
1984.
PUBLISHED BY:
THE HINDUSTAN TIMES. NEW .
of Bachchan's call for violence against
Times in itsNovember 1984 report
Sikhs were targeted during November
DELHI
NOV 1, 1984
SOURCE: LIBRARY OF CONGRESS NEWSPAPER RM
Complaint
SFJ, et al. v. Amitabh Bachchan
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
G
o
9. Perils caused by Bachchan's call for
violence against Sikhs continue to be
unearthed even after more than two decades. Starting with the 2011
discovery of Mass Grave of Sikhs in
village Hondh-Chillar, District Rewari,
states of India including additional
Haryana, the evidence located in sev jral
nine (9) Gurudwara ruins in Delhi,
Gurgaon, Stateof Haryana; ruins of
Pradesh and Jammu & Kashmir
trass cremation site in Pataudi and
Sikh localities in West Bengal, Uttar
the gravity, span, compass and
spread nature of the attacks initiated
exposes
specially organized, identical and wide
ciscovery coming twenty-six years after
enocide of Sikhs that tookplace
of the cover up that began all those
by the call given by Bachchan. This
the fact is evidence not only ofthe g<
throughout India at the time but also
years before which continues tothis day.
10. Consequences ofBachchan's venomous slogans for Sikh Blood can be seen
even today in doomed "Widow Colony
Delhi. Originally known as "Tilak ViHar
", a locality of Indian Capital New
, "the widow colony" is almost
ch men who were killed in "The Sikh
entirely inhibited by widows of the S
Genocide of 1984" and where hardships
persist continuously as a result of thos
were set in motion by the call to violence given by Bachchan
Complaint
SFJ, et al. v. Amitabh Bachchan
struggles, and extreme poverty
5dreadful and unlawful events, that
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
J
1l.The defendant was at the time ofNovember 1, 1984 heavily involved in
politics in India and was aknown supporter and long-time family friend of
Rajiv Gandhi, the son of Prime Minister Indira Gandhi, who took the office
of Prime Minister immediately after the assassination of his mother and
became the youngest person to hold that office as well as a scion of the
politically powerful Nehru-Gandhi family associated with the Indian
National Congress (I) party.
12.In the same year of the assassination
of Indira Gandhi, Bachchan, mostly
ging the death of Ms. Gandhi, was
certainly as a reward for his role in a]/en
nominated as Congress party candidate in general elections and he won a
seat on the 8th Lok Sabha (the Parliament
of India) by one of the highest
of India. This also shows the
victory margins in the election history
popularity and influence that Bachchan
to direct violence against Sikhs. This
in instigating and inciting the killing bfSikhs during November 1984
13.Sikhs are a religious minority in Indie
and are largely residing in the Indian
enjoyed at that time which he used
was after his egregious and active role
, a Hindu majority -controlledcountry,
state of Punjab. In 1984 the ruling
Congress (I) party with Indira
party in the center was the Indian National
Gandhi as the leader and Prime Minister of the country
Complaint
SFJ, et al. v. Amitabh Bachchan
-7
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
Q
Q
14.0n October 31, 1984, Prime Minister Gandhi was shot by two of her own
body guards who happened to be Si^hs.
15.Almost 24 hours later, on November
Sikhs began in India and particularly
almost unhindered to November 4, 1
Sikh men, women, and children were
1, 1984, an organized targeting of
the capital New Delhi which continued
?84. In the four day carnage, 30,000
killed in New Delhi alone while
thousands were left maimed, woundejd
and Sikhtemples were ransacked, locked
300,000 Sikhs were displaced.
16.From November 1, 1984 till about
raped and burnt. Shops, properties
and torched. As a result, more than
November 4, 1984 over 30,000 members
ofthe Sikh community were ruthlessly
maimed, and subject to both theft and
included places of worship. The attacks
thus genocidal innature targeting merfrbers
did not ignore the cries of innocent
killed, butchered, burnt alive, raped,
destruction of private property that
were inherently discriminatory and
of the Sikh religion in India and
men, women, and children who were
either killed orbattered and abused beyond
recognition. Groups were formed
e violence that was initiated bythe
Amitabh Bachchan.
during rampages of looting andincish
words of one man, that is the Defendant
Complaint
SFJ, et al. v. Amitabh Bachchan
-8
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
Q
17.lt is noteworthy that the news of the
attack on Prime Minister Gandhi did not
bring any immediate peril on Sikhs but rather, almost 24 hours later after a
smear campaign against Sikhs was
initiated by Defendant, a systematic and
of the Congress (I) party began to
virtue of any means available. There are
organized effort on part of the leaders
eradicate the Sikh population by
living witnesses who tell of personal
Bachchan chanting on the radio and
observations of the Defendant Amitabh
in
personwith slogans of hate, fear,
and in effigysigningthe death
-filled and murder-consuming,
Bachchan quickly spread like
dozens of cities throughout the entire
rtually
anger, bloodlust, and vengeance vir
warrants of thousands of Sikhs. The
hate
vengeful propaganda of Defendant Anitabh
the plague throughout New Delhi and
country ofIndia. During the melee, people were instigated, provoked,
organized and then given arms and ammunition to kill Sikhs in New Delhi to
avenge the death of Prime Minister Gindhi
During the four day rampage,
Delhi alone, hundreds of women were
more than 30,000 Sikhs were killed in
gang raped, hundreds of homes were
were attacked and burnt to the ground
18.The individual plaintiffs are victims
witnessed the atrocities first hand and
looted, and scores of Sikh Temples
and survivors of the massacre who
lad lost family members, friends, and
Complaint
SFJ, et al. v. Amitabh Bachchan
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
o
Q
loved ones killed during those events. The organization plaintiff, Sikhs For
Justice, Inc. ("SFJ") is a U.S.-based iuman rights organization dedicated to
achieving justice for the Sikh population who suffered during the
aforementioned 1984 events in India
19.Moreover, on October 31,1984, the ,lay before the massacre, the defendant
raised the slogans "khoon ka badla khoon se lenge" ("Blood for Blood") and
"Blood Stains of Indira Ji must reach
popularly aired on Indian radio.
20.This unleashed widespread panic due
the home of Sikhs" which were
to a following systematic and
organized series ofattacks against the Sikh community that ended with the
deaths ofmore than 30,000 Sikhs in z. short span of4days all across India.
2Lit is well known that the defendant us^d his "Super Star status" to incite
violence against Sikhs.
22.The defendant's political ties to the Gandhi family shielded him from bein:
investigated and prosecuted during the last three decades
23.The mass killing of Sikhs, tantamount to an attempt at genocide, was widely
reported in the world press and was widely condemned by the western
nations and international media, including the media of India. One article
published by the Hindustan Times ofNew Delhi on November 1, 1984
Complaint
SFJ, et al. v. Amitabh Bachchan
- 10
ffi
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
o
shows a cartoon map of the Indian
thousands of innocent Sikh men,
of the chaos that erupted from the ca
Amitabh Bachchan . The map
subcontinent drenched in the bloodof
numerous cities and places in India vfhere
specifically Delhi, Jammu & Kashmir.
Jharkhand, Uttarakhand, Madhya Pradesh
Chattisgarh, Andhra Pradesh, Bihar,
Kerala, Orissa, andTripura to name a
PUBLISHED BY:
THE HINDUSTAN TIMES. NEW-
women, and children who died as a result
1of violence given bythe Defendant
pinpoints, highlights, and calls attention to the
the Sikhs were massacred,
, Himachal Pradesh, Haryana,
Maharastra, Uttar Pradesh,
amil Nadu, West Bengal, Gujarat,
few. The map appears below:
DELHI
NOV 1, 1984
SOURCE: LIBRARY OF CO]
JGRESS NEWSPAPER RM
Complaint
SFJ, et al. v. Amitabh Bachchan
11
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
24.This is acivil action for compensato y
defendant Amitabh Bachchan for vi

and punitive damages against

violations of state, federal and
international law committed against ihe Plaintiffs, specifically the law of
nations, customary international law,
the Convention on the Prevention and
treaties ofthe United States including
Punishment of the Crime of Genocide
of 1948, the Alien Tort Statute, the
federal common lawwho, at all relevant
Torture Victim Protection Act and
state law ofthe state ofIndia and witi
Government of India.
times, were acting under color of
the actual or apparent authority of the
II. JURISDICTION AND VENUE
25.Plaintiffs allege that Defendant is liable
, jointly and severally, for genocide,
against humanity, forced exile,
3and genocide and for conspiring with
aforementioned conduct. Therefore,
ion based on the Alien Tort Statute,
ionAct, Pub. L. No. 102-256,
C. 1350 (note)) ("TVPA"), federal
extrajudicial killings, torture, and crimes
attempted extrajudicial killings, tortur
and aiding and abetting others in the
this Court has jurisdiction over this ac
28 U.S.C. 1350, the Torture Victim Protection
106 Stat. 73 (1992) (codified at 28 U.S.
common law and 28 USC 1331.
26.Venue, upon information and belief, is
Complaint
SFJ, et al. v. Amitabh Bachchan
- 12
proper in the Central District of
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
O
California, Western Division- Los ;^n
(c), and (d) because Defendant recently
o
lgeles pursuant of28 USC 1391 (b),
conducted substantial business
through Hollywood film industry,
American movie "The Great Gatsby'
Hollywood film industry which is located
of this court.
including his major role in the famous
made, sponsored and released by the
within the territorial jurisdiction
27. This Court has personal jurisdiction
Fed. R. Civ. P. and N.Y.C.P.L.R. 301
of the Defendants pursuant toRule 4,
(McKinney2010).
III. PARTIES
A. Named Plaintiffs
28.Plaintiff "Sikhs for Justice" is a legal
the State of New York with a 501(c)
seek justice for those killed in November
entityregistered and incorporated in
(not for profit) status, working to
1984 Sikh Massacre. Plaintiff sues
(3)
on behalf of all the members of Sikhs
community that were injured or whose
during the massacre of November
family members were killed or injurec
1984. Plaintiff Mohender Singh and rrjany other victims of"Sikh Genocide
of 1984" are members of the Association SFJ. SFJ brings this action on
behalf ofits members who were tortured or had family members who were
Complaint
SFJ, et al. v. Amitabh Bachchan
13
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
Q
O
tortured or killed in the violence that resulted from the call ofviolence
against Sikhs initiated by Bachchan on October 31, 1984.
29.Plaintiff Babu Singh Dukhiya is aSiich, national and citizen of India. During
the massacre of November 1984 he lost several members of his family to the
groups that were motivitated and instigated by the call of violence against
Sikhs given by defendant Bachchan end were lead by Congress (I) party
leaders. Plaintiff Babu Singh Dukhiyn's family home was looted,
vandalized, and destroyed. Plaintiff a
situated i.e. those who were attacked
so sues on behalfof others similarly
killed or injured during the massacre
ofNovember 1984. Plaintiff Babu Singh Dukhiya is also President ofthe
National 1984 Victims Justice and Welfare Society, an organization started
to fight for the victims of The Sikh Genocide of 1984 who have been
repeatedly denied justice in India for more than 30 years.
30.Plaintiff Mohinder Singh is Sikh national and citizen ofIndia, current
resident of the State of California and previously aresident ofNew Delhi,
India. During the massacre ofNovember 1984, several members ofhis
family includinghis father were killed
by the mobs that were instigated by
the slogans ofBachchan and were leac by Congress (I) leaders. Plaintiff also
Complaint
SFJ, et al. v. Amitabh Bachchan
14
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

sues on behalf of others similarly

killed or injured during the massacre
B. Named Defendant
31.Defendant is a citizen and national o
against the Sikh population in 1984,
Gandhi family. After the October 31
Bachchan and mostly certainly as a
of Ms. Gandhi, in December 1984
party candidate in general elections
(the Parliament ofIndia) by one oftht
election history of India. This also
Bachchan enjoyed at that time which
Sikhs. This was after his egregious
the killing of Sikhs during November
32.During the "Sikh Genocide of 1984",
overtly took part in instigating, incitin
Sikh population of India and caused
retaliation of Prime Minister Gandhi's
was seen and heard by countless throu.
Complaint
SFJ, et al. v. Amitabh Bachchan
sit jated
o
i.e. those who were attacked,
of November 1984.
India. At the time of the horrific events
defendant was a close affiliate to the
assassination of Indira Gandhi,
reward for his role in avenging the death
defendant was nominated as Congress
he won a seat on the 8th Lok Sabha
aid
highest victory margins in the
the popularity and influence that
shows
le used to direct violence against
active role in instigating and inciting
1984.
and
Defendant Bachchan actively and
and provoking the attacks against
killing of innocent Sikhs in
the
death. Specifically, the Defendant
$hout India on the Indian television
15
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

and radio broadcast shouting out repoa

o
itedly intones of blood-thirsty
stains of Indira Ji must reach the
vengeance "Blood for Blood" and "E;lood
homes of Sikhs." Inthe particular
the attackers who killed and injured
were shoutingthe slogans that were
that they were instigated by the call
Instigated bythe defendant's call, the
raped Sikh women, assaulted, beat
destroyed Sikh homes and places of
in broad daylight bythe mobs in the
words and actions were a major deci
unfoldedresulting in the deaths of
inci
dents involving individual plaintiffs,
the plaintiffs and their family members
liaised by the defendant, clearly linking
dfviolence given by the defendant,
mobs captured Sikhs, killed Sikhs,
aikd maimed Sikhs, as well as looted and
worship. Many Sikhs were burnt alive
presence of thousands. Defendant's
decisive turning point in the events that
over thirty thousand Sikhs.
C. Class Allegations
33.The class consists partly of all men,
the lawful attacks on them and on thei
women
and children who are surviving
families and properties during the
sufferedeither physical or mental
massacre of November 1984 and who
injuries or loss of property or loss of
of the defendant. The class also consists
representatives of the next of kin of thckse
companionship as a result of the actions
Complaint
SFJ, et al. v. Amitabh Bachchan
16
of next of kin of the legal/personal
Sikhs who were killed in New
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
c
o
Delhi India during November 1984 ifiassacre in which the defendant
voluntarily took part and planned anjd directed the same
34.The exact number of class members
Indian Government put the number o|f
days at around 30,000; however, ther^
be far greater.
s not known. The official figures of the
Sikhdeaths duringthose four fateful
are those who believe the death toll to
35.The claims of the named Plaintiffs,
the claims of the class. The named
the class representatives, are typical of
plaintiffs are able to and will fairly and
class.
adequately protect the interests of the
36.There are common questions of law
relate to each member of the class inc
ajid fact in this action that affect and
uding:
a. Whether the defendant instigated and abetted the killings ofSikhs
Massacre of Sikhs in India by inciting,
nst Sikhs to avenge the death of Prime
during the November 1984
given a call for violence aga
Minister Gandhi,
b. Whether the defendant, as a
close friend and affiliate of tlhe
a following and influence ov0r
fact exercise such influence
Complaint
SFJ, et al. v. Amitabh Bachchan
17
oowerful iconic figure as film star and
powerful ruling Gandhi family had
the people in India and he did in
tohave the Sikh population targeted
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

for unprovoked and vengeance

subsequently used his influ|ence
9
-motivated attacks and killings, and
and connections to save himself
from being prosecuted and assisted in the massive cover up of the
genocidal acts November 1984.
c. Whether the defendants act ons during the November 1984
massacre ofSikhs, give rise to liability under applicable
international and domestic laws.
37.This action is properly maintained as
acted and failed toact ina way ge
declaratory relief award appropriate
of law and fact common to the class
a class action because: a) the defendant
applicable to the class, making any
the class as a whole; and b) questions
predominate over questions affecting
is superior to other available methods
nerally
to
individual members and a class action
for the fair and efficient adjudication of the controversy
IV. STATEMENT OF FACTS
Background
38.The Nation of India is a Federal
Prime Minister who is an elected
governed by the "Central" or "Union"
"Central Government") which is
Complaint
SFJ, et al. v. Amitabh Bachchan
Parliamentary Republic that is headed by a
representative of the people. India is
Government (hereinafter
comprised of numerous departments,
18
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

agencies and ministries. There are t

that are governed by elected official
wenty-eight3 states or provinces in India
called Chief Ministers who in turn
encies, departments and instrumentalities
appoint officials to run the local ag
of the state. The Central Governmem
controlled and otherwise run bythe
seats inthe Parliament and State Assemblies
Central Government is located in the
municipal government is traditionall)
political party in power in the Central
and the states are administered,
political party that holds the majority of
, respectively. The seat of the
capital city of New Delhi. New Delhi's
administered and controlled by the
Government.
33. In October and November of 1984
the Indian National Congress (I)
oolitical party of the Central
party ("Congress (I)") was the ruling
Government ofIndia with a majority
also in control ofthe local government
and November 1984 Congress (I) also
twenty-two Indian States. In other woifds
inthe Indian Parliament and, thus, was
of NewDelhi. Moreover, in October
held majorities in eighteen of the
, Congress (I) virtuallyhad
of India in October and November
complete control over the governance
1984.
24
25
26
5
In October-November 1984, India consistec
additional states were carved out in later years
Complaint
SFJ, et al. v. Amitabh Bachchan
- 19
of only twenty-five (25) states. Three
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
O
36. The Prime Minister of India in 1
984 was Indira Gandhi, the daughter of
of India post- Independence and
Gandhi and Nehru were leaders of
Jawaharlal Nehru, the first Prime Minister
protegee of Mahatma Gandhi. Both
Congress (I) following independence
leader of Congress (I) at the time she
in 1947and Indira Gandhi was the
served as Prime Minister.
38. On October 31, 1984, Prime Minister
body guards who happened to be Sikhs
then Prime Minister ofIndia and head
dead at All India Institute of Medical
Amitabh Bachchan, raised the slogans
("Sikhs have killed Indira"); "Maro
("Kill these bastards , they aretraitors
ghar ghar tak puhnchanay chahiyay'"
households of Sikhs") and "khoon ka
Hearing defendant Bachchan's call for
Gandhi was shot bytwoof her
Immediately, after Indira Gandhi the
of ruling Congress party was declared
Sciences (AIIMS), the Defendant
'Sikho ne Indira Ji ko mar dala'
Jjaalon ko, desh ke ghaddaron ko"
); 'khoon ke cheentay Sikhon ke
("the blood stains should reach the
?adla khoon" ("blood for blood"),
violence against Sikhs, otherwise
shocked and numb crowd immediatel>
present in the crowd and started beatin
reacted violently towards Sikhs
39. In less than twenty-four hours, an
throughout India began particularly in
Complaint
SFJ, et al. v. Amitabh Bachchan
-20
g them.
organized targeting of Sikhs
he capital of New Delhi that
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
0
9
continued unabated until November
4, 1984.
40. During the four day rampage,
Delhi alone and more than 30,000
women were gang raped, children
and properties were looted and
ransacked and burned to the ground
were displaced.
rrore
were
wore
than 3,000 Sikhs were killed in New
killed all over India, hundreds of
brutally tortured, hundreds ofhouses
and scores of Sikh temples were
More than 300,000 Sikhs across India
destroyed
42. Taking alead from the slogans
after the death of Indira Gandhi
headquarters located at 24Akbar
November 1, in which leaders and
Jagdish Tytler, Sajjan Kumar, HKL B
Kamal Nath.
rased
meetin
by the defendant immediately
gs were held Congress (I)
New Delhi on October 31, 1984 and
ofofCongress party including
lagat, Lalit Maken, Arjun Das and
Road
members
44. Taking a cue from the defendant's
Sikhs, leaders and officials of Congrest
and in some instances word for word n
"Khoon ka badla khoon" (blood for bl
ghar tak pahunchni chahiye" (splashes
idea ofinflammatory slogans against
(I) delivered inflammatory speeches
|peated the defendant's slogans
d) and "khoon ki chintey sikhon ke
ofblood should reach the doorsteps
CO
Complaint
SFJ, et al. v. Amitabh Bachchan
-21
1
2
3
4
5
6
7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
o
of Sikhs) inorder to incite a genocidal riot directed at the Sikhs ostensibly to
avenge the death of Indira Ghandi.
49. Congress party network and state machinery and resources were used
carry out and facilitate the call of violence initiated by the defendant. During
October and November1984, Congress (I) ruled and controlled 18 states and
had thus complete control over its paityapparatus as well as state machinery
which it used against Sikhs.
B. Defendant's Participation and tole
50. Defendant single-handedly raised the first slogans calling for violence
against Sikhs which instigated the messes tokill Sikhs by chanting slogans
that promoted the deaths of Sikhs resulting in violence andrampage
terrorizing thousands and leaving thousands more dead intheir wake. During
the time frame of October 31, 1984 to November 4, 1984, the defendant,
having close relationship ties tothe family of the then Prime Minister of
India Indira Gandhi, and also having
close ties to the ruling party the Indian
National Congress (I) party, instigated the violence against Sikhs resulting in
attack on Sikh lives, homes, business, and places of worship. The groups
that attacked the named plaintiffs and their families andhomes, wereclearly
instigated by the vengeful call of the
Complaint
SFJ, et al. v. Amitabh Bachchan
defendant as the assailants during
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
%
attacks repeated the same slogans that were coinedby the defendant and
broadcast through TV and radio throughout India. The defendant's slogan
had helped in creating an atmosphere and desensitizing the human senses
and dehumanizing the Sikhs to such an extent that there were occasions
when the police were present at the soene of the occurrences but instead of
preventing the attack, they either joined the attackers or stood by silently.
C. Inadequacy of Local Remedies
51. Upon information and belief, as practical matter and proven fact, no
adequate remedies are available to Plaintiffs under the Indian system. In fact
after more than 30 years of massacre, the Indian government and its
prosecuting agencies have failed to prosecute and convict a single leader
including the defendant Bachchan who was responsible for instigating
widespread killings of Sikhs. In the case of Bachchan, such has been his
influence and connections with the powers to be that he was immediately
rewarded with seat in the Parliament and has since then not even been
investigated. All efforts by or on behalf of the plaintiffs to seek adequate
remedy against Bachchan have been countered by the fruitless, and it seems
impossible that even after 30 years, the plaintiffs will be able to seek justice
against this defendant in India.
Complaint
SFJ, et al. v. Amitabh Bachchan
-2:
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
tfl
f3k
General A legations
52. The acts described in this Comolaint were instigated and abetted by
the defendant using his position and i ifluence.
53. The acts and injuries to Plaintijfs and their deceased relatives
described herein, as well as those similarly situated, part of a pattern and
practice ofsystematic human rights violations instigated and abetted by the
defendant and carried out in most cases by Congress-I workers, followers
and fans of the defendants and other individuals, who were motivated by the
call of violence against Sikhs given by Bachchan.
FIRST CLAIM FOR RELIEF
(Crimes against Humanity; Genocide, Rape, Torture, Summary Executions}
54. Plaintiffs re-allege and incorporate byreference the allegations set
Forth in paragraphs 1through 54 ofthis Complaint as if fully set forth
herein.
55. The actions committed by the defendant against Plaintiffs and
Decedents constitute Crimes against
humanity committed with deliberation,
knew or should have known that
planning andprecision. Defendant
instigating the public sentiments ag
amst a vulnerable and unarmed religious
minority and painting the minority community as a whole "responsible for
Complaint
SFJ, et al. v. Amitabh Bachchan
-24
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
c Q
the death of their leader would result in death, destruction and injuries to the
innocent Sikhs. As such, the defendant was responsible for the physcial
injuries andmental torture to the survivors, murder of decedents, andthese
wrongs knowingly committed as part
against a civilian population.
of a widespread or systematic attack
56. Defendant, by virtue of this inhuman act, also caused great suffering
And /or serious injury to body and/or
to mental or physical health in the
context of a widespread or systematic attack against a civilianpopulation to
Plaintiffs and to Descendant's next of kin.
57. Defendant's acts and omissions constitute "tort[s].. .committed in
violation of the law of nations or a treaty of the United States" under 28
U.S.C 1350 and also violate 28 B31 in that the acts and omissions
against Plaintiffs violated customary
international law prohibiting war
crimes as reflected, expressed, and definedin multilateral treaties and other
international instruments, international and domestic judicial decisions, and
other authorities.
58. The acts and omissions constituting crimes against humanity caused
Plaintiffs to suffer damages, including severe physical and mental pain and
suffering, in amounts to be determined at trial.
Complaint
SFJ, et al. v. Amitabh Bachchan
25
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
o
Q
59. Defendant's acts and omissions were deliberate, willful, intentional,
wanton, malicious, and/or oppressive, and should bepunished by an award
of punitive damages in an amount tobe determined at trial.
SECOND CLAIM FOR RELIEF
(Cruel, Inhuman, or degrading Treatment or Punishment)
60. Plaintiffs re-allege andincorporate by reference the allegations set
forth in paragraphs 1through 59 ofthis complaint as if fully set forth herein.
61. The abuses committed against Plaintiffs andDecedents described
herein each separately constitutes cruel, inhuman or degrading treatment or
punishment and were instigated and ^betted by the defendant. These acts
include, but are not limited to: the intentional and illegal burning of
residential neighborhood resulting in
severe physical and psychological
abuse and agony, humiliation, fear and debasement; the injury and death of
family members during such burning, resulting in profound fear, loss, and
anguish.
62. Defendant's acts also constitute torts committed in violation of the
lawof nations, andthus of the United States, as reflected in federal common
law which incorporated extrajudicial
killing, pursuant to 28 U.S.C 1331
a violation of the law of nations and
and 1350. Thus, the conduct constitutes
customary international law prohibit: ng Cruel, Inhuman, or degrading
Complaint
SFJ, et al. v. Amitabh Bachchan
26
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
o O
Treatment or Punishment as reflected, expressed, and defined in multilateral
treaties and other international instruments, international and domestic, and
judicial decisions and other authorities. Extrajudicial killing is similarly
reflected, expressed, defined and codi fied in multilateral treaties and other
instrumental instruments, international and domestic judicial decisions, and
other authorities, and is thus actionab
e.
63. Defendant's acts and omissions described caused Plaintiffs to suffer
damages, including severe mental and emotional pain and suffering in an
amount to be proven in trial.
64. Defendant's acts and omissions were deliberate, willful, intentional,
Wanton, malicious and oppressive, and should be punished by an award of
punitive damages in an amount to be determined at trial.
THIRD CLAIM FOR RELIEF
(Extrajudicial Killing)
65. Plaintiffs re-allege and incorporate by reference the allegations set
Forth in paragraphs 1through 64 ofthis complaint as if fully set forth herein
The killings ofDecedent's were deliberate and not authorized by a previous
judgment pronounced by a regularly constituted court affording all the
judicial guarantees that are recognized
Complaint
SFJ, et al. v. Amitabh Bachchan
-27
as indispensable by civilized peoples.
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
tfl
66. The killings were not lawfully earned out under the authority of any
countryor court. The killings of Decedents constitute extrajudicial killings
as Defined by the Torture Victim Protection Act, Pub .L. No. 102-256,106
Stat.73 (1992) (codified at 28 U.S.C
1350, note). Additionally, the killings
constitute torts committed in violation of the law of the nations, and thus of
the United States, as reflected in federal common lawwhich incorporates
extrajudicial killings as a violation, pursuant to 28 U.S.C. 1331 and
1350.The conduct of the defendant constitutes violations of the law of
nations and customary international lawprohibitingextrajudicial killing,
reflected, expressed, defined and codified in multilateral treaties and other
international instruments and domestic); judicial decisions and other
authorities.
67. Defendant knew or should have known that instigating the public
sentiments against a vulnerable and unarmedreligious minority and painting
the minority community as a whole "responsible for the death of their leader,
arming the public and providing the oil and other arms to the goons and
stopping the police from saving the lives of Sikhs encircled by angry mob of
several thousand people would result in death, destruction and injuries to the
innocent Sikhs. As such, Defendant was responsible for the murder of
Complaint
SFJ, et al. v. Amitabh Bachchan
28
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
o
Q
Decedents, andthese murders were knowingly committed as part of a
widespread or systematic attack against a civilian population.
68. Defendant's acts and omissions caused Plaintiffs and Decedent's next of
kinto suffer damages, including severe physical and mental pain and
suffering in amounts to be determined at trial.
69. Defendant's acts and omissions wsre deliberate, willful, intentional,
wanton, malicious, and/or oppressive,
and should be punished by an award
of punitive damages in an amount to be determined at trial
FOURTH CLAIM FOR RELIEF
(Wrongful Death)
70. Plaintiffs re-allege and incorporate; by reference the allegations set forth
in paragraphs 1through 69 of this complaint as if fully set forth herein
71. Defendant was closely affiliated and connectedto the Congress-I, the
then ruling party and family of the late: Prime Minister Indira Gandhi. The
defendant owed a duty to Decedents because they were foreseeable victims
as of the open call for violence givenby the defendant by vengeful chanting
of blood-thirsty slogans on October 31, 1984
Complaint
SFJ, et al. v. Amitabh Bachchan
29
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
^%
^fk
72. Defendant's acts and omissions described herein caused Plaintiffs, other
members of class and all ofDecedent:? next to kin, to suffer damages,
including pecuniary damages, inan amount to beproven at trial.
Defendant's acts and omissions were deliberate, willful, intentional, wanton,
malicious, and/or oppressive, and should be punished byan award of
punitive damages in an amount to be determined at trial.
FIFTH CLAIM FOR RELIEF
(Negligence)
73. Plaintiffs re-allege and incorporates byreference the allegations set
forth inparagraphs 1through 72 of this Complaint as if fully set forth herein
Defendant owned a duty to Plaintiffs and Decedents because they were
foreseeable victims of the blood thirsty slogans raised by the defendant after
the assassination of Indira Gandhi.
74. Defendant being a close affiliate o
the ruling party, the Indian National
Congress (I) andclose affiliate and connected to the ruling family of the late
Prime Minister Indira Gandhi of the Indian government, owed a duty to
Decedents to refrain from intentional and wantonly harmful or outrageous
conduct. Defendant owed a duty to Decedents because they were foreseeable
victims of the vengeful and blood thirsty slogans that raised in public after
the assassination of Indira Gandhi.
Complaint
SFJ, et al. v. Amitabh Bachchan
30
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
Q
o
75. Beyond mere negligence, Defendant's acts were deliberate, willful,
intentional, wanton, malicious, and/or oppressive, and should be punished by
an award ofpunitive damages in addition to compensatory damages, in
respective amounts to be determined at trial.
SIXTH CLAIM FOR RELIEF
(Public Nuisance)
76. Plaintiffs re-allege and incorporate by reference the allegations set forth
in paragraphs 1through 76 ofthis Complaint as if fully set forth herein.
Defendant deliberately and unreasonably interfered withthe aforementioned
rights by authorizing, commanding, and directing the attack on Sikhs, and
particularly on Gurdawar Rakab Ganj.
77. The public nuisance created by Defendant directly caused Plaintiffs to
suffer special injuries and damages, unique from those suffered by the public
at large. The nuisance interfered with,
individual rights.
obstructs, and/or injuries, Plaintiffs
78. Defendant's acts and omissions we;re deliberate, willful, intentional,
wanton, malicious, and/or oppressive.
79. Defendant's acts and omissions described
nuisance and directly caused Plaintiffs
including pecuniary damages, in the amount to be proven at trial.
Complaint
SFJ, et al. v. Amitabh Bachchan
-31
herein constituted a public
and Decedents to suffer damages,
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
A
o
SEVENTH CLAIM FOR RELIEF
(Battery)
80. Plaintiffs re-allege and incorporate by reference the allegations set forth
inparagraphs 1through 79 of this Complaint as if fully set forth herein.
81. Defendant instigated the public against the Sikhs, where Defendant knew
or should have known that his actions
would result in death and injuries to
innocent members of Sikh community who were besieged therein
Defendant intended to bring about this; contact.
82. As a direct and proximate cause of Defendant's conduct, Plaintiffs,
other members of class and their Decedents were harmed. It was reasonably
foreseeable that the attack would cause this harm
83. Defendant's acts and omissions caused Plaintiffs to suffer damages
including severe physical andmental pain and suffering, in amounts to be
determined at trial.
84. Defendant's acts and omissions wexe deliberate, willful, intentional
wanton, malicious, and/or oppressive, andshould be punished by an award
of punitive damages in amount to be determined at trial
EIGHTH CLAIM
(Intentional Infliction ip
Complaint
SFJ, et al. v. Amitabh Bachchan
-32
FOR RELIEF
rfEmotional Distress)
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
o
0
85. Plaintiffs re-allege and incorporate by reference the allegations set forth
in paragraphs 1through 84 of this Complaint as if fully set forth herein.
86. Defendant instigated the public ag;
ainst the Sikhs instigated and abetted
the killing of Sikhs by raising anti-Sikh slogans, where Defendant knew or
should have known that his actions would result indeath and injuries to
innocent Sikhs.
86. Defendant intended to causePlaintiffs to suffer humiliation, mental
anguish andextreme emotional distress or, alternatively, Defendant
recklessly disregarded a substantial probability of causing humiliation,
mental anguish, and severe emotional distress to Plaintiffs with his conduct
As a direct and proximate cause of Defendant's outrageous conduct,
Plaintiffs suffered severe emotional distress and mental suffering. It was
reasonably foreseeable that his words would cause this suffering
87. Defendant's acts and omissions were deliberate, willful, intentional,
wanton, malicious, and/or oppressive, and should be punished by an award
of punitive damages in an amount to b
NINTH CLAIM
(Negligent Infliction 0,
88. Plaintiffs re-allege and incorporate
determined at trial.
FOR RELIEF
f Emotional Distress)
by reference the allegations set forth
in paragraphs 1through 87 of this Complaint as if fully set forth herein
Complaint
SFJ, et al. v. Amitabh Bachchan
33
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
o
^m
89. Defendant owed a duty to Plaintiffs to refrain from intentional and
wantonly harmful or outrageous conduct of raising slogans calling for
violence against Sikhs.
90. By raising slogans calling for the violence against Sikhs, directing an
outrageous, wantonly violent attack on the Sikhs, Defendant violated this
duty and created an unreasonable and foreseeable risk of substantial bodily
harm or death tothe Plaintiffs. The attack placed the Plaintiffs ingrave
danger and/or made them reasonably fear for their physical safety
91. Plaintiffs have suffered and will continue to suffer extreme mental
anguish and emotional distress that was directly caused by the trauma,
shock, and fear that they experienced duringand directly after the violent
attacks orchestrated by the Defendant.
92. Moreover, Defendant's conduct caused the named Plaintiffs and other
members of the class and their immed
ate families suffer violent deaths or
grave physical injury. Defendant's cor duct was a substantial factor in
bringing about the injuries and deaths :o which Plaintiffs bore witness.
93. In this manner, Defendant negligently inflicted severe emotional distress
upon Plaintiffs. Defendant's acts and emissions caused Plaintiffs to suffer
damages in amounts to be determined at trial.
Complaint
SFJ, et al. v. Amitabh Bachchan
34
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
|R
A
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for ju^
a) For compensatory damages in a|n
b) For punitive and exemplary daiina
trial;
c) For reasonable attorney's fees abd
d) For a declaratory judgment holdjin
violation of the laws of nations
e) For a declaratory judgment holdin
against Sikhs was "Genocide" a$
laws of the United States.
f) For such other and further relief
proper.
A jury trial is demanded on all issues.
Dated: October 27, 2014
gment against Defendant as follows:
amount to be proven at trial;
ges in an amount to be proven at
cost of suits;
g that Defendant's conduct was in
g that November 1984 violence
defined under international laws and
as the Court may deem just and
Complaint
SFJ, et al. v. Amitabh Bachchan
Babak
75-20
Jacksob
(718)
Pourtavoosi, Esquire, SBN 216287
Astoria Boulevard, Suite 170
Heights, NY 11370
672-8000; Fax: (718) 732-4514
Bpesq2@yahoo.com
Attorney for Plaintiffs
35
UNITED STATES DISTRICT COURT,
CIVIL COVER
CENTRAL DISTRICT OF CALIFORNIA
SHEET
U ORIGINAL
I. (a) PLAINTIFFS ( Check box if you are representing yourself Q )
SIKHS FORJUSTICE, INC., BABU SINGH DUKHIYA, and MOHINDER SINGH on their
own behalf and on behalf of deceased and injured family members and others
DEFENDANTS ( Check boxifyouare representing yourself | [
AMITABH BACHCHAN
Clounty of Residence of First Listed Defendant N/A
(IIJU.S. PLAINTIFFCASESONLY)
(b)Countyof Residence of First Listed Plaintiff NewYork County
(EXCEPTINU.S. PLAINTIFF CASES)
(c) Attorneys {Firm Name, Address and Telephone Number) Ifyou are
representing yourself, provide the same information.
Babak Pourtavoosi, Esquire, SBN 216287 LawOffices of Babak Pourtavoosi, Esq.
75-20 Astoria Boulevard, Suite 170
Jackson Heights, NY11370
(718) 672-8000; Fax:(718) 732-4514
II. BASIS OF JURISDICTION (Place an Xin one box only.)
I 11. U.S. Government
Plaintiff
Ix] 3.Federal Question (U.S.
Government Not a Party)
Attorneys {Firm Name, Address and Telephone Number) Ifyou are
r presenting yourself, provide the same information.
N/A
(Pla
Citizen of
Citizen of
III. CITIZENSHIP OF PRINCIPAL PARTIES-For Diversity Cases Only
:e an Xin one box for plaintiff and one for defendant)
PTF DEF , , . n ...D, PTF DEF
restate i i ^!^!!tZlI^mce 4
of Business in this State
Another State [] 2 [] 2 Incorporated and Principal Place D 5 D 5
of Business in Another State
cLXfa 3 3 ForeignNation
I I 2. U.S. Government
Defendant
I 14. Diversity (Indicate Citizenship
of Parties in Item III)
Citizen or
Foreign
6 6
IV. ORIGIN (Place an Xin one box only.)
pi 1.Original ii 2. Removed from
" Proceeding '' State Court
II 3. Remanded from ii 4.Reinstated or
II Annellate ( ourt II Appellate Court Reopened
6. Multi-
S.Transferred fromAnother ii District
District (Specify) II Litigation
V. REQUESTED IN COMPLAINT: JURY DEMAND: [x] Yes No
CLASS ACTION under F.R.Cv.P. 23: [x]Yes No [X
(Check "Yes" only if demanded in complaint.)
MONEY DEMANDED IN COMPLAINT: $ TBD
VI. CAUSE OF ACTION (Cite the U.S. Civil Statute under which you are filingand w
Alien Tort Statute, 28 U.S.C.1350 and the Torture Victim Protection Act, Pub. L No. 102-;
human rightsviolations, includinggenocide, crimesagainst humanityand variouscivil
ite a brief statement of cause. Do not cite jurisdictional statutes unless diversity.)
56,106 Stat. 73 (1992) (codified at 28 U.S.C.1350). Acivil action for various civil and
claims.
VII. NATURE OF SUIT (Place an Xin one box only).
%MWmi^t-'~;
375 False Claims Act
rI 400 State
II Reapportionment
410 Antitrust
| | 430 Banks and Banking
450 Commerce/ICC
Rates/Etc.
fj 460 Deportation
470 Racketeer Influ
enced &Corrupt Org.
|~~| 480 Consumer Credit
490 Cable/Sat TV
850 Securities/Com
modities/Exchange
890 Other Statutory
Actions
891 Agricultural Acts
893 Environmental
Matters
895 Freedom of Info.
Act
Q 896 Arbitration
899 Admin. Procedures
| | Act/Review of Appeal of
Agency Decision
950 Constitutionality of
State Statutes
FOR OFFICE USE ONLY:
CV-71 (06/14)
f;^""CONTRACT'
| | 110 Insurance
120Marine
130Miller Act
rI 140 Negotiable
l' Instrument
150 Recovery of
II Overpayment &
Enforcement of
Judgment
fj 151 Medicare Act
152 Recovery of
DefaultedStudent
Loan (Excl. Vet.)
153 Recovery of
| | Overpayment of
Vet. Benefits
rl 160 Stockholders'
LJ Suits
p1 190Other
Contract
rI 195Contract
L-J Product Liability
196Franchise
REAL PROPERTY
rj 210Land
Condemnation
| | 220 Foreclosure
230 Rent Lease &

Ejectment
REAt*PffOfgRSrcM
240Tortsto Land
rj 245 TortProduct
Liability
[J 290All OtherReal
Property
TORTS
PERSONAL INJURY
Q 310Airplane
315 Airplane
Product Liability
r-, 320 Assault, Libel&
LJ Slander
330 Fed. Employers'
Liability
fj 340Marine
345 Marine Product
Liability
350MotorVehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury-
Med Malpratice
365 Personal Injury-
Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
__ 368 Asbestos
I I Personal Injury
Product Liability

', ~\ 37k) Other Fraud

i - - - - -
|~~| 37|1 TruthinLending

wwsm
At 2 Naturalization
ication Arjpl
465 Other
Immigration Actions
TORTS '
PERSONAL PROPERTY
38:0 Other Personal
Property Damage
385
ER PETITIONS IISONERPEI
Habeas Corpus:
[J 463Alien Detainee
510 Motions to Vacate
Sentence
530General
535DeathPenalty
Property Damage
Prfjduct Liability
540Mandamus/Other
550Civil Rights
r1 555 Prison Condition
560 Civil Detainee
LJ Conditions of
Confinement Bankruptcy

4; 2 Appeal 28
"158 U!C
3 Withdrawal 28
157 use
flVILWGHTSjgg
"FORFEITURE/PENALTY
625 Drug Related
LJ Seizure ofProperty 21
USC 881
690Other
*
D

4^0 Other Civil Rights

1 Voting
<.;-,'i.s"'" LABOR
710 Fair Labor Standards
Act
11 720 Labor/Mgmt.
' Relations
[J 740Railway Labor Act
751 Family and Medical
Leave Act
rI 790Other Labor
I Litigation
791 Employee Ret. Inc.
Security Act
412
44 3
44 5
Di
Employment
Housing/
Accommodations
American with
jabilities-
Er iployment
American with
;abilities-Other
4^6
d,
Q 448 Education
Case Number:
CVU-Q8297
CIVIL COVE KSFTEET
PROPERTY RIGHTS : |
820Copyrights
830Patent
840Trademark
. SOCIALSECURITY.
861HIA(1395ff)
862Black Lung (923)
863DIWC/DIWW (405 (g))
864SSID Title XVI
865RSI (405 (g))
FEDERALTAX SUITS.
(1 870Taxes (U.S. Plaintiff or
I' Defendant)
r-, 871IRS-Third Party26 USC
L-l 7609
Page 1 of 3
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVE *!
VIII. VENUE: Your answers to the questions belowwill determine the divisionof the
tochange, inaccordance with the Court's General Orders, upon review bytheCourt of
SHEET
Court to which this case will be initiallyassigned. Thisinitialassignment is subject
r Complaint or Notice of Removal. you
QUESTION A: Was this case removed
from state court?
Yes fx] No
If"no," skip to Question B. If"yes,"check the
box to the right that applies, enter the
corresponding division in response to
Question E, below, and continue from there.
STATECASE WAS PENDING IN THE COUNTYOF: INITIAL DIVISION IN CACD IS:
| | LosAngeles,Ventura,Santa Barbara,c r San Luis Obispo
Western
Q Orange
| | Riverside or San Bernardino
: '<. $fey-;?%/j
,) 3-'-'':*& -:"
mfr*&/fi:M-:&&/:'<<-:>^:-' 5>i$.
B.I. Do 50%or more of the defendants w(io reside in
the district reside in Orange Co.?
checkone of theboxestotheright "**
QUESTION B: Is the United States, or
one of its agencies or employees, a
PLAINTIFF in this action?
Yes [x] No
If"no," skip to Question C. If"yes," answer
Question B.I, at right.
w 10 reside in
Bernardino
er.)
B.2. Do 50% or more of the defendants
the district reside in Riverside and/or San
Counties? (Consider the two counties toi
check one of the boxes to the right
gi ;the
-$. >g^-jWfjK<^---'*S?V
reside in the C.I. Do 50% or more of the plaintiffs who
district reside in Orange Co.?
check oneofthe boxes tothe right ^^
QUESTION C: Is the United States, or
one of its agencies or employees, a
DEFENDANT in this action?
Yes fx] No
If"no," skip to Question D. If"yes,"answer
Question C.I, at right.
C.2. Do 50% or more of the plaintiffs who
district reside in Riverside and/or San Bernard
Counties? (Consider the two counties
check one ofthe boxes to the right
reside in the
ino
er.) ; tog ;th<
Southern
Eastern
hs:^'^sM^m&
YES. Your case will initiallybe assigned to the Southern Division.
f_] Enter "Southern" inresponse to Question E, below, andcontinue
from there.
Q NO. Continueto QuestionB.2.
YES. Your case will initiallybe assigned to the Eastern Division.
[~~| Enter "Eastern"in response to Question E,below, and continue
from there.
NO. Your case will initially be assigned to the Western Division.
| | Enter "Western"in response to Question E,below, and continue
from there.
YES. Your case will initiallybe assigned to the Southern Division.
Enter "Southern" inresponseto Question E, below, andcontinue
from there.
Q NO. Continue to Question C.2.
YES. Your case will initially be assigned to the Eastern Division,
fj Enter "Eastern" inresponse to Question E, below, andcontinue
from there.
NO. Yourcase will initiallybe assigned to the Western Division,
fj Enter "Western" inresponse to Question E, below, andcontinue
from there.
QUESTION D: Location of plaintiffsland defendants?
Orange County
B.
Riverside or San
Bernardino County
Los An'gejes, Ventura',;
Santa Barbara, or San'
Luis ObispaCoUnty'-'
Indicate the location(s) in which 50% or more of plaintiffswho residein this
reside. (Check up to two boxes, or leave blank if none of these choices apply.)
distiict
Indicate the location(s) in which 50% or more of defendants who residein this
district reside. (Checkup to two boxes, or leave blank ifnone of these choices
apply)
-..: "^fiiMm^sm-f.mm is&ji^y\^.'yv!y-:
D.I. Is there at least one answer in Column A?
Yes [Xj No
If"yes," your case willinitiallybe assigned to the
SOUTHERN DIVISION.
Enter"Southern" in response to Question E, below, and continue from there.
If "no," gotoquestion D2 tothe right. "^^
QUESTION E: Initial Division?
Enter the initial division determined by Question A, B, C, or Dabove:
QUESTION F: Northern Counties?


''"M^^^Vk^^'t
D.2. Is there at least one answer in Column B?
Yes (X] No
If"yes,"your case will initiallybe assigned to the
EASTERN DIVISION.
Enter "Eastern" in response to Question E, below.
If"no,"your case will be assigned to the WESTERN DIVISION.
Enter "Western" in response to Question E, below.
INITIAL DIVISION IN CACD
WESTERN
Do 50% or more of plaintiffs or defendants in this district reside in Ventura, Santa Barbara, or San Luis Obispo counties? Q Yes [x] No
CV-71 (06/14)
CIVIL COVE R SHEET
Page 2 of3
UNITED STATES DISTRICT COURT,
CIVIL COVElR
CENTRAL DISTRICT OF CALIFORNIA
I SHEET
IX(a). IDENTICAL CASES: Has this action been previously filed in this
Ifyes, listcase number(s): N/A
cour:?
IX(b). RELATED CASES: Is this case related (as defined below) to any cases previously filed in this court?
Ifyes, listcase number(s): N/A
Civil cases are related when they:
A. Arise from the same orclosely related transactions, ha
B. Call for determination of the same or substantially related or
C. For other reasons would entail substantial duplication of labo
ppenmg, or event;
similar questions of lawand fact; or
r ifheard bydifferent judges.
(X] NO YES
NO YES
Check all bo^pthat apply. That cases may involve the same patenl,
related.
trademark, or copyright isnot, initself, sufficient to deemcases
X. SIGNATI/RE OF ATTORNEY
(OR SELF-REPRESENTED LITIGANT):
Notice toCounsel/Parties: The submission of this Civil Cover Sheet is required
neither replaces nor supplements the filing and service ofpleadings orother
more detailed instructions, seeseparate instruction sheet (CV-071 A).
DATE: 10/27/2014
by Local Rule 3-1. This Form CV-71 andtheinformation contained herein
papers as required by law, except as provided by local rules of court. For
Key toStatistical codes relating toSocial Security Cases:
Nature of Suit Code Abbreviation
861
862
863
863
864
865
CV-71 (06/14)
HIA
BL
DIWC
DIWW
SSID
RSI
SubstantiveStatement of Ca|ise of Action
Allclaims for health insurance benefits
include claimsby hospitals, skillednursinc
(42U5.C.1935FF(b)) *
(Medicare)
under Title 18, Part A, oftheSocial SecurityAct, asamended Also
facilities, etc., for certification asproviders ofservices under the program.
All claimsfor "Black Lung" benefits under
923)
fitle 4, Part B, oftheFederal Coal Mine Health and Safety Act of1969. (30 U.S.C.
All claims filed by insured workers for d
all claims filed for child's insurance benefit^
Allclaims filed for widows or widowers i
amended. (42 U.S.C. 405 (g))
All claims for supplemental security incorrJe
amended.
lity insurance benefits under Title 2oftheSocial Security Art, asamended; plus
basedondisability. (42 U.S.C. 405(g))
benefits based on disability under Title 2ofthe Social Security Act, as
payments based upon disability filed under Title 16 ofthe Social Security Act, as
sa 3il
All claimsfor retirement (oldage) and <
(42 U.S.C. 405(g))
surv ivors benefits under Title 2oftheSocial Security Act, asamended.
CIVIL COVER SHEET
Page 3 of3