IN THE SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES

HALLE BERRY,
Plaintiff,

v.

ROBERT DOWNEY JR.,
Defendant.

Case No.: [To Be Assigned]

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COMPLAINT FOR DAMAGES

(Personal Injury – Pain and Suffering, Negligence)

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I. PARTIES

1. Plaintiff, Halle Berry (“Plaintiff”), is an individual residing in the State of California and, at all relevant times, was a professional actress engaged in film production.
2. Defendant, Robert Downey Jr. (“Defendant”), is an individual residing in the State of California and, at all relevant times, was a professional actor working on the motion picture Gothika.

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II. JURISDICTION AND VENUE

3. This Court has jurisdiction over the subject matter of this action and the parties hereto.
4. Venue is proper in this Court because the घटनाओं giving rise to this action occurred in Los Angeles County, California.

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III. GENERAL ALLEGATIONS

5. On or about the filming of the motion picture Gothika, Plaintiff and Defendant were engaged in a scene requiring physical interaction.
6. During said filming, Defendant negligently, carelessly, and recklessly performed a physical action which resulted in Plaintiff sustaining a serious injury to her arm.
7. As a direct and proximate result of Defendant’s conduct, Plaintiff suffered a broken arm requiring medical treatment, rehabilitation, and interruption of her professional obligations.
8. Plaintiff endured significant physical pain, emotional distress, and mental anguish arising from the injury.
9. The injury forced delays in production, caused professional embarrassment, and resulted in loss of income and future opportunities.
10. Plaintiff continues to suffer residual effects, including but not limited to pain, limited mobility, and emotional distress associated with the incident.

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IV. CAUSE OF ACTION – NEGLIGENCE

11. Plaintiff incorporates by reference all preceding paragraphs.
12. Defendant owed Plaintiff a duty of care to act reasonably and safely during the filming of physically demanding scenes.
13. Defendant breached that duty by failing to exercise reasonable care and control during the scene.
14. Defendant’s breach directly caused Plaintiff’s injuries.
15. As a result, Plaintiff has suffered:

• Physical pain and suffering
• Emotional distress
• Medical expenses
• Loss of earnings and earning capacity
• Other damages according to proof

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V. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests judgment against Defendant as follows:

1. General damages for pain and suffering in an amount to be determined at trial;
2. Special damages, including medical expenses and lost wages;
3. Compensation for emotional distress;
4. Costs of suit incurred herein;
5. Such other and further relief as the Court deems just and proper.

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VI. DEMAND FOR JURY TRIAL

Plaintiff hereby demands a trial by jury on all issues so triable.

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DATED: [Insert Date]

Respectfully submitted,

[Attorney Name]
Attorney for Plaintiff
Halle Berry