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Attorneysfor PlaintiffFabian Zanzi JUN 2
1
8
I
14 JOHN TRAVOLTA, an individual;
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
Defendant.
JURISDICTION AND VENUE
1. This Court has jurisdiction over this action pursuant to 28 U.S.c. 1331 and/or
1333 in that the events, transactions and/or occurrences at issue transpired at a cruise ship
Plaintiff, FABIAN ZANZI ("Plaintiff') hereby alleges as follows against Defendant
JOHN TRAVOLTA ("TRAVOLTA")
en:2 5393 )
) COMPLAINT FOR:
) 1) ASSAULT AND BATTERY;
) 2) INTENTIONAL INFLICTION OF
) EMOTIONAL DISTRESS;
) 3) NEGLIGENT INFLICTION OF
EMOTIONAL DISTRESS
)
)
)
)
)
)

when said ship was navigating the open seas ("navigable waters").
27
2. Venue is proper in this Court pursuant to 28 U.S.C. 1391(b).
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11 FABIAN ZANZI, an individual;
12 Plaintiff,
13 vs.
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1
COMPLAINT
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ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
1. Defendant TRAVOLTA is, and during all time periods pertinent to this
action was, an individual residing, conducting substantial professional and personal
business in the State of California, County of Los Angeles.
2. Plaintiff, during all time periods pertinent to this action, was an employee of
Royal Caribbean Cruise, Ltd ("RCC"). Plaintiff was engaged by RCC to work on a cruise
ship ("MS Enchantment of the Seas") destined to tour the Caribbean Sea commencing on
or about June 8, 2009 ("the cruise").
3. Defendant TRAVOLTA was a guest/passenger ofRCC's MS Enchantment
of the Seas cruise. Plaintiff was assigned as the personal room attendant for Defendant
TRAVOLTA. Attached hereto and incorporated herein by this reference as EXHIBIT 1 is
a true and correct copy of a correspondence relating to Plaintiffs assignment as Defendant
TRAVOLTA's personal attendant. EXHIBIT 1 illustrates the favorable treatment
provided by RCC to Defendant TRAVOLTA which included the provision to Plaintiff of a
paging device ("beeper") so that Defendant TRAVOLTA could access Plaintiff at any time
during the cruise.
4. On or about June 9, 2009, at approximately 4:00 p.m., while the MS
Enchantment of the Seas cruise ship was in navigable waters, Defendant TRAVOLTA
ordered a meal from RCC's room service. Plaintiff, having been assigned as the personal
room service attendant for Defendant TRAVOLTA, tended to Defendant TRAVOLTA's
order.
5. Plaintiff delivered Defendant TRAVOLTA's meal order to his suite. At the
time of this initial delivery, Defendant TRAVOLTA was accompanied by two other males.
After Plaintiff completed the delivery, and as he was departing Defendant TRAVOLTA's
suite, Defendant TRAVOLTA made an additional food order directly from Plaintiff.
Plaintiff complied and advised Defendant TRAVOLTA that he would return with the
additional order shortly.
6. After approximately twenty (20) minutes, Plaintiff returned to Defendant
2
COMPLAINT
As Plaintiff reached for the bathrobe/neck area, Defendant TRAVOLTA
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TRAVOLTA's suite to serve Defendant TRAVOLTA's additional meal order. At this
time, Defendant TRAVOLTA was alone in his suite. Defendant TRAVOLTA was wearing
a bath robe.
7. After Plaintiff served Defendant TRAVOLTA's meal order, Defendant
TRAVOLTA ordered Plaintiff to stay and accompany him in his room. Defendant
TRAVOLTA ordered Plaintiff to take a seat. Plaintiff, aware that Defendant TRAVOLTA
was an important guest of RCC (Plaintiffs employer), and that Plaintiffs duties as a
room! suite attendant required ensuring the comfort of guests, complied with Defendant
TRAVOLTA's requests/ orders.
8. After conversing for a few minutes, Defendant TRAVOLTA requested
Plaintiff to take some of Defendant TRAVOLTA's clothes from one area of the suite to
another. Plaintiff complied.
9. While Plaintiff was in the process of performing Defendant TRAVOLTA's
errand request, Defendant TRAVOLTA approached Plaintiffs person and told Plaintiff
that he was experiencing discomfort on his neck area. Defendant TRAVOLTA then
solicited physical contact from Plaintiff. Defendant TRAVOLTA pleaded for Plaintiff to
touch his (Defendant TRAVOLTA's) neck.
10. As Defendant TRAVOLTA was motioning towards an area behind his
neck, Plaintiff assumed that Defendant TRAVOLTA was referring to and complaining
about the label tag of his bathrobe [or some other agent of Defendant TRAVOLTA's
bathrobe].
11.
proceeded to disrobe. As a result, Defendant TRAVOLTA became completely naked
exposing his erect penis to Plaintiff.
12. After disrobing in front, and close proximity, of Plaintiff, Defendant
TRAVOLTA proceeded to forcefully embrace Plaintiff. Defendant TRAVOLTA forced
his naked person and his erect penis against Plaintiffs person causing Plaintiff to
experience pain, shock, embarrassment, distress, and fear.
3
COMPLAINT
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1 13. Defendant TRAVOLTA stated to Plaintiff that he was beautiful and asked
2 Plaintiff to "take me, I will take care ofyou, please... "
3 14. Plaintiff pleaded with Defendant TRAVOLTA that he be released from
4 Defendant TRAVOLTA's embrace. Plaintiff advised Defendant TRAVOLTA that he
5 needed to return to his work. Defendant TRAVOLTA continued to restrain Plaintiff.
6 Defendant TRAVOLTA maintained a hard and painful grasp on Plaintiffs hands.
7 Defendant TRAVOLTA continued pressing his erect penis against Plaintiffs person
causing Plaintiff to continue to experience pain, shock, embarrassment, distress, and fear.
15. The contact between Defendant TRAVOLTA's person and Plaintiffs
person was nonconsensual, inappropriate, extreme, and outrageous.
16. Defendant TRAVOLTA requested for Plaintiff to maintain his silence about
the events that transpired in Defendant TRAVOLTA's suite.
17. In exchange for Plaintiff's discretion and silence, Defendant TRAVOLTA
offered Plaintiff a sum of money totaling $12,000.00. Defendant TRAVOLTA advised
Plaintiff to return to his suite later on that same night to collect the $12,000.00 payment
from Defendant TRAVOLTA.
18. After leaving Defendant TRAVOLTA's suite, Plaintiff remained in a state
of pain, shock, embarrassment, distress and fear. Plaintiff immediately reported the
incident to his superiors.
19. Plaintiff met with at least three (3) cruise ship supenors [each RCC
employees]- a director, human resources manager and a staff captain- to discuss the events
that transpired in Defendant TRAVOLTA's suite. Plaintiff alleges that he met with RCC's
Human Resources Manager Lorena Alvarez; RCC's Director Michael Rasmussen; and
RCC's Staff Captain Esben.
20. On or about June 9, 2009 at approximately 7:00 p.m., RCC's Human
Resources Manager Lorena Alvarez required Plaintiff to fill out paperwork regarding the
incident with Defendant TRAVOLTA. Ms. Alvarez refused to allow Plaintiff to write
down any information regarding the nudity and/or sexual contact with Defendant
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COMPLAINT
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TRAVOLTA. Ms. Alvarez advised Plaintiff that the report was strictly limited to the
details regarding Plaintiffs discipline for touching Defendant TRAVOLTA's neck and
that Plaintiff was not permitted to document any additional information. Ms. Alvarez
further advised Plaintiff that unless he was bleeding or bruised, he did not suffer any
injuries and thus could not obtain treatment or any other type of attention.
21. During the reporting of the incident with Ms. Alvarez, Plaintiff requested
that he complete the report in Spanish as that was his native language. Plaintiff advised
Ms. Alvarez that he was not comfortable writing in English. Despite, Plaintiffs requests,
Ms. Alvarez required Plaintiff to fill out the reports in question solely in the English
language. Ms. Alvarez further advised Plaintiff that he may be fired.
22. Plaintiff was ordered by RCC's agents, employees, and/or representatives to
stay in a segregated room until Defendant TRAVOLTA departed from the cruise ship.
Plaintiff was restrained in said room for five (5) days. Plaintiff was not allowed to go
outside this segregated room. Plaintiffs attempts to speak with human resources were
consistently ignored. RCC's human resources agent advised Plaintiff that he was
considered on "sick leave" until further notice.
23. During the period of July 2009 through July 2011, Plaintiff was persistent in
contacting RCC for the purpose of filing a claim against Defendant TRAVOLTA. Plaintiff
alleges that RCC continually advised him that a claim was being filed and that he needed
to check back at a later time. Plaintiff alleges that RCC did nothing to resolve Plaintiff's
claims.
24. Plaintiff began seeking treatment for injuries sustained from the above
mentioned incident on or about July 2009. Plaintiff continues to pursue treatment for the
above referenced injuries.
25. Plaintiff has filed an Arbitration Demand with the American Arbitration
Association with respect to his claims against RCC.
II
II
II
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COMPLAINT
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FIRST CAUSE OF ACTION
(ASSAULT AND BATTERY)
AS AGAINST DEFENDANT TRAVOLTA
26. Plaintiff incorporates paragraphs 1 through 25 of this Complaint as though
fully set forth herein.
27. Plaintiff brings this cause of action pursuant to general Admiralty Law as
the resulting injury to Plaintiff was suffered while aboard the MS Enchantment of the Seas
cruise vessel which, during the time period in question, was navigating open seas.
28. On June 9, 2009 at approximately 4:40 p.m., while aboard RCC's cruise
ship, the MS Enchantment of the Seas, harmful and offensive contact was forced by
Defendant TRAVOLTA onto Plaintiff s person.
29. On June 9, 2009, at approximately 4:40 p.m., Defendant TRAVOLTA acted
with the intent to cause harmful and offensive contact to Plaintiff and his person by
removing his bath robe, grabbing Plaintiff's hand, and forcing his naked person and erect
penis against Plaintiff's person.
30. Defendant TRAVOLTA was successful in causing actual contact between
his naked person and Plaintiff's person.
31. Defendant TRAVOLTA, while naked and erect, embraced Plaintiff and did
not release Plaintiff for a period oftime.
32. Plaintiff did not consent to the offensive, inappropriate, outrageous,
extreme, and embarrassing contact by Defendant TRAVOLTA.
33. Plaintiff alleges on information and belief that Defendant TRAVOLTA
intended to cause such a harmful and offensive contact and intended to cause Plaintiff to
fear the imminent non-censual contact.
34. Plaintiff experienced fear and apprehension as a result of the
aforementioned contact from Defendant TRAVOLTA.
35. In addition, Plaintiff alleges that a reasonable person would be harmed and
offended by Defendant TRAVOLTA's actions in forcing his naked body and erect
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COMPLAINT
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penis against Plaintiff s person and subsequently embracing Plaintiff, holding his erect
penis forcefully against Plaintiffs body, and not letting Plaintiff escape Defendant
TRAVOLTA's grasp all while Plaintiff repeatedly requested release from Defendant
TRAVOLTA's grasp.
36. As a direct and proximate result of Defendant TRAVOLTA's actions in
harmfully and offensively making contact with Plaintiffs person, Plaintiff suffered
damages in an amount that will be proven at trial. Defendant TRAVOLTA also acted
intentionally, willfully, and maliciously for the purpose and with the intent to offend, harm,
and/or oppress Plaintiff. Plaintiff is therefore entitled to exemplary and punitive damages
in an amount to be proven at trial or as the Court deems just and proper.
SECOND CAUSE OF ACTION
(INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS)
AS AGAINST DEFENDANT TRAVOLTA
37. Plaintiff incorporates paragraphs 1 through 36 of this Complaint as though
fully set forth herein.
38. Plaintiff brings this cause of action pursuant to the general law of Admiralty
as Plaintiff s injury was suffered while aboard the MS Enchantment of the Seas cruise
vessel which, during the time period in question, was navigating open seas.
39. On or about June 9, 2009, at approximately 4:40 p.m., while aboard the MS
Enchantment of the Seas cruise vessel, Defendant TRAVOLTA acted in an extreme and
outrageous manner when he exposed his naked body and erect penis to Plaintiff, grabbed
PlaintifPs hand, and then embraced Plaintiff, thereby forcing his naked body and erect
penis against PlaintifPs person.
40. Defendant TRAVOLTA was III a position of power over Plaintiff as
Plaintiff was specifically and specially assigned as Defendant TRAVOLTA's personal
room service attendant. Please see EXHIBIT 1. In addition, RCC held Defendant
TRAVOLTA as a very important guest. RCC demonstrated its willingness to tend to all of
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COMPLAINT
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Defendant TRAVOLTA's requests even when doing so was in violation RCC's established
rules and practice. Attached hereto and incorporated herein by this reference as EXHIBIT
2 is a true and correct copy of an email correspondence from RCC showing an admission
of preferential treatment accorded to Defendant TRAVOLTA.
41. Plaintiff alleges that Defendant TRAVOLTA acted with knowledge that his
actions would certainly cause emotional distress in Plaintiff as any reasonable person,
when embraced by a naked and erect person holding a superior position, in a forceful and
nonconsensual manner, would certainly be distressed to a severe extent.
42. Plaintiff suffered severe emotional distress as a result of Defendant
TRAVOLTA's actions in intentionally embracing Plaintiff while naked and erect and
subsequently not allowing Plaintiff to leave Defendant TRAVOLTA's room when Plaintiff
requested to du suo
43. Plaintiff did receive, and is still currently receiving, independent treatment
for the severe emotional distress he suffered as a result of Defendant TRAVOLTA's
extreme and outrageous actions.
44. As a direct and proximate cause of Defendant TRAVOLTA's actions,
Plaintiff suffered damages in an amount that will be proven at trial. Defendant
TRAVOLTA also acted intentionally, willfully, and maliciously for the purpose and with
the intent to offend, harm, and/or oppress Plaintiff. Plaintiff is therefore entitled to
exemplary and punitive damages in an amount to be proven at trial or as the Court deems
just and proper.
THIRD CAUSE OF ACTION
(NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS)
AS AGAINST DEFENDANT TRAVOLTA
45. Plaintiff incorporates paragraphs 1 through 44 of this Complaint as though
fully set forth herein.
46. Plaintiff brings this cause of action pursuant to the general law of Admiralty
8
COMPLAINT
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as Plaintiffs injury was suffered while aboard the MS Enchantment of the Seas cruise
vessel which, during the time period in question, was navigating open seas.
47. In the alternative to Plaintiffs cause of action for Intentional Infliction of
Emotional Distress against Defendant TRAVOLTA, Plaintiff brings this cause of action
alleging that Defendant TRAVOLTA acted negligently in engaging in conduct causing
Plaintiff to suffer severe emotional distress as a result of Defendant TRAVOLTA's
extreme and outrageous conduct in exposing his naked body and erect penis to Plaintiff
and subsequently embracing Plaintiff, thereby forcing his naked body and erect penis onto
Plaintiffs person.
48. As a direct and proximate result of Defendant TRAVOLTA's extreme and
outrageous conduct, Plaintiff suffered extreme and severe emotional distress.
49. Plaintiff continues to undergo therapy as a result of Defendant
TRAVOLTA's conduct.
50. As a direct and proximate result of Defendant TRAVOLTA's conduct,
Plaintiff has suffered damages in an amount that will be proven at trial. Defendant
TRAVOLTA also acted intentionally, willfully, and maliciously for the purpose and with
the intent to offend, harm, and/or oppress Plaintiff. Plaintiff is therefore entitled to
exemplary and punitive damages in an amount to be proven at trial or as the Court deems
just and proper.
II
II
II
9
COMPLAINT
Servando Timbol, Esq.
Sarah J. Golden, Esq.
Attorneysfor PlaintiffFabian Zanzi
Golden & Timbol, PC.
1 WHEREFORE, Plaintiff, having set forth the claims for relief against Defendant,
2 respectfully prays that this Court grant the following relief:
3 1. for compensatory damages in an amount to be proven at trial;
4 2. for consequential damages in an amount to be proven at trial;
3. for punitive damages in an amount to be proven at trial;
4. for such other and further relief as the court may deem just and proper.
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Date:
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COMPLAINT
EXHIBIT 1
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EN Bar Manager/E.NIRCLShip

To EN F&8
cc' EN AsslslantBar Manager/EN/RCLShip@ROLShip, EN
ChiefHousekeeperIEN/RCLShip@RCLShip, EN Guest
ServicesManC'lger(ENlRCLShip@flCLShip,EN Ho.tel
Subject Re: DC'lilyset up Travplta and few things
. " :.
Sk,
. Everything is done fOftonight setup;.Jllanks,
David Kirton
Beverage Manager
Office': 4;121 .
Pager #508.. .' ...........
'ENCHANTMENTOF'sEAs
... .
.
EN F&BManagerlEN/RCLShip
-...
cc ENAssiSfaritgarManagerlENlRClSllip(g)RCtShip, EN Bar
ManagerIENIRCLShip@RCLShip, EN
. EN Hotel
Director/EN/ROLShip@8CLShip,EN
EN RoomSelVice
Supef'iisorIENlRCLShiP.@8GLShip.. . .
. ....
Hola Rosita,
Thank youfor putlingus in the alert, wewill definitely,comply with what has been requested, her is my
underStanding and Indications to my team. ifanyof What-IselinyoiJ feel is not in accordance to what
Mr.Travoit have stated asa request,piease letmeknow--sQwecari make tile changes,
Michael:1 believe if YOU: agreed, we. can make a.nexceptiontQ.the rules, and send'the alcoho(,
pleaSe let know so Jcan <:ii>prove the. setup, ....
COORDiNATE \\.'1Tl:i ROOM$'ERYICE SUPEF{V(SOHT:O.[jIk1GENTLYMANAGE
THIS REQUEST, 1.like tosu,ggest that we:assign' Mr. Fatiian.Z.anzi to take persOnal care of this requEl$t,
he has' proven.to bec:J discrete and kiJ.owle.qgf*3ble of rOOm seNice;
Please make sure we give Rosa Fabial)'srlame as the F&Broom SE;!'rvicecphtact, get 'Fabian a
and infonn Rosa she (;an give ino Mr, TraVolta.' ..
EXHIBIT 2
Manager/ENiRCLShip
To EN
EN EN Bar
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EN Hotel
DirectQriENlRClShip@HCLShip, EN . .
EN Room 8eNice
SupervisorJENIRCLShip@RCLShip .
Subject Re:.Dail)' setl.,/p"for Mr. Travolta and few things
"thank you in advance foryourvall)able
Kind regards,
LuisAcosta "
Associate Hotel Direcior
MSEnchantment oftheSeas
. EN Guest Manager/ENlRClShip
EN Guest Services
UNITED STAWDISTRICT COURT, CENTRAL DISTRlta>F CALIPORNI.i.
CIVIL COVER SHEET -
, .
/
I (a) PLAINTIFFS (Check box if you are representing yourself D) DEFENDANTS
FABIAN ZANZI, an individual
JOHN TRAVOLTA, an individual
(b) Attorneys (Firm Name, Address and Telephone Number. If you are representing
yourself, provide same.)
Golden & Timbol, P.c.
151 Kalmus Dr., Ste#A-204
Costa Mesa. CA 92626/714-360-0100
Attorneys (If Known)
Lavely & Singer, P.c.
2049 Century Park East., Ste#2400
Los Angeles, CA 90067
II. BASIS OF JURISDICTION (Place an X in one box only.) III. CITIZENSHIP OF PRINCIPAL PARTIES - For Diversity Cases Only
(Place an X in one box for plaintiff and one for defendant)
02 U.S. Government Defendant 04 Diversity (Indicate Citizenship Citizen of Another State
of Parties in Item III)
DIU,S. Government Plaintiff ri3 Federal Question (U.S.
Government Not a Party) Citizen of This State
PTF DEF PTF DEF
01 01 Incorporated or Principal Place 04 04
of Business in this State
02 02 Incorporated and Principal Place 05 05
of Business in Another State
Citizen or Subject ofa Foreign Country 0 3 0 3 Foreign Nation 06 06
o 2 Removed from 0 3 Remanded from 0 4 Reinstated or
State Court Appellate Court Reopened
IV. ORIGIN (Place an X in one box only.)
Iii Original
Proceeding
o 5 Transferred from another district (specify): 06 Multi-
District
Litigation
o 7 Appeal to District
Judge from
Magistrate Judge
V. REQUESTED IN COMPLAINT: JURY DEMAND: 0 Yes IiNo (Check 'Yes' only if demanded in complaint.)
CLASS ACTION under F.R.C.P. 23: 0 Yes riNo 0 MONEY DEMANDED IN COMPLAINT: $
VI. CAUSE OF ACTION (Cite the U.S. Civil Statute under which you are filing and write a brief statement of cause. Do not cite jurisdictional statutes unless diversity.)
VII. NATURE OF SmT (Place an X in one box only.)
OTHER STATUTBS CONTRACT TORTS PRlSQNElf
0400 State Reapportionment 0110 Insurance PERSONAL INJURY PERSONAL PETITIONS 0710 Fair Labor Standards
0410 Antitrust 0120 Marine 03IO Airplane
PROPERTY 0510 Motions to Act
0430 Banks and Banking 0130 Miller Act
0315 Airplane Product
0370 Other Fraud Vacate Sentence 0720 Labor/Mgmt.
0450 CommercellCC 0140 Negotiable Instrument
rl320
Liability
0371 Truth in Lending Habeas Corpus Relations
Rates/etc. 0150 Recovery of
Assault, Libel &
0380 Other Personal 0530 General 0730 Labor/Mgmt.
0460 Deportation Overpayment &
Slander
Property Damage 0535 Death Penalty Reporting &
0470 Racketeer Influenced Enforcement of
0330 Fed. Employers'
0385 Property Damage 0540 Mandamus/ Disclosure Act
and Corrupt Judgment
Liability
Product Liability Other 0740 Railway Labor Act
Organizations 0151 Medicare Act
0340 Marine
BA.NK.RUPTCY 0550 Civil Rights 0790 Other Labor
0345 Marine Product
0480 Consumer Credit 0152 Recovery of Defaulted
Liability
0422 Appeal 28 USC 0555 Prison Condition Litigation
0490 Cable/Sat TV Student Loan (Excl.
0350 Motor Vehicle
158 FORFEITUREI 0791 Empl. Ret. Inc.
0810 Selective Service Veterans)
0355 Motor Vehicle
0423 Withdrawal 28 PENALTY Security Act
0850 Securities/Commodities/ 0153 Recovery of
Product Liability
USC 157 0610 Agriculture PROPERTYRlolttS
Exchange Overpayment of
0360 Other Personal
CIVILRIGHTS 0620 Other Food & 0820 Copyrights
0875 Customer Challenge 12 Veteran's Benefits
Injury
0441 Voting Drug 0830 Patent
USC 3410 0160 Stockholders' Suits
0362 Personal Injury-
0442 Employment 0625 Drug Related 0840 Trademark
0890 Other Statutory Actions 0190 Other Contract
Med Malpractice
0443 Housing/Acco- Seizure of SOCIALSECUR1TY
0891 Agricultural Act 0195 Contract Product
0365 Personal Injury- mmodations Property 21 USC 0861 HIA (I 395ff)
0892 Economic Stabilization Liability Product Liability 0444 Welfare 881 0862 Black Lung (923)
Act 0196 Franchise 0368 Asbestos Personal 0445 American with 0630 Liquor Laws 0863 D1WC/DIWW
0893 Environmental Matters REAL PROPERTY Injury Product Disabilities - 0640 R.R. & Truck (405(g))
0894 Energy Allocation Act 0210 Land Condemnation Liability Employment 0650 Airline Regs 0864 ssmTitle XVI
0895 Freedom ofInfo. Act 0220 Foreclosure IMMIORAnON 0446 American with 0660 Occupational o 865RSI (405(l\)!
0900 Appeal of Fee Determi- 0230 Rent Lease & Ejectrnent
0462 Naturalization
Disabilities - Safety /Health fEDERAL.TAXSt1lTS .
nation Under Equal 0240 Torts to Land
Application
Other 0690 Other 0870 Taxes (U.S. Plaintiff
Access to Justice 0245 Tort Product Liability
0463 Habeas Corpus-
0440 Other Civil or Defendant)
0950 Constitutionality of 0290 All Other Real Property
Alien Detainee
Rights 0871 IRS-Third Party 26
State Statutes
0465 Other Immigration
USC 7609
Actions
FOR OFFICE USE ONLY:
Case Number: _
AFTER COMPLETING THE FRONT SIDE OF FORM CV-71, COMPLETE THE INFORMATION REQUESTED BELOW.
CV-71 (05/08) CIVIL COVER SHEET Page lof2
UNITED STAiij DISTRICT COURT, CENTRAL DISTRIft)F CALIFORNIA.
CIVIL CQVER Sm;ET .,
VIII (a). IDENTICAL CASES: Has this action been previously filed in this court and dismissed, remanded or closed? rJt'No DYes
If yes, list case number(s): ------------------------------------------------------
VIII(b). RELATED CASES: Have any cases been previously filed in this court that are related to the present case? MNo DYes
If yes, list case number(s): _
Civil cases are deemed related if a previously filed case and the present case:
(Check all boxes that apply) D A. Arise from the same or closely related transactions, happenings, or events; or
DB. Call for determination ofthe same or substantially related or similar questions of law and fact; or
DC. For other reasons would entail substantial duplication of labor if heard by different judges; or
D D. Involve the same patent, trademark or copyright, and one of the factors identified above in a, b or c also is present.
IX. VENUE: (When completing the following information, use an additional sheet if necessary.)
(a) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named plaintiff resides.
D Check here if the its or employees is a named plaintiff. If this box is checked, /!,O to item (b).
County in this District:' California County outside of this District; State, if other than California; or Foreign Country
Chile
(b) List the County in this District; California County outside of this District; State ifother than California; or Foreign Country, in which EACH named defendant resides.
D Check here if the its or employees is a named defendant. Ifthis box is checked, /!,o to item (c).
County in this District:" California County outside of this District; State, if other than California; or Foreign Country
Los Angeles County
(c) List the County in this District; California County outside of this District; State ifother than California; or Foreign Country, in which EACH claim arose.
Note: In land condemnation cases, use the location of the tract of land involved.
County in this District:" California County outside of this District; State, if other than California; or Foreign Country
Between Mexico and Belize in a cruise while said ship was in navigable waters
* Los Angeles, Orange, San Bernardino, Riverside, Ventura, Santa B
Note: In land condemnation cases use the location of the tract ofland inv
X. SIGNATURE OF ATTORNEY (OR PRO PER): Date 6/20/12
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Notice to Counsel/Parties: The CY-71 (1S-44) Civil Cover Sheet d t e information contained herein neither replace nor supplement the filing and service of pleadings
or other papers as required by law. This form, approved by the Judicial ference of the United States in September 1974, is required pursuant to Local Rule 3-1 is not filed
but is used by the Clerk ofthe Court for the purpose ofstatistics, venue and initiating the civil docket sheet. (For more detailed instructions, see separate instructions sheet.)
Key to Statistical codes relating to Social Security Cases:
Nature of Suit Code Abbreviation
861 HIA
BL
863 D1WC
863 D1WW
864 SSID
865 RSI
Substantive Statement of Cause of Action
All claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended.
Also, include claims by hospitals, skilled nursing facil ities, etc., for certification as providers of services under the
program. (42 U.S.c. 1935FF(b))
All claims for "Black Lung" benefits under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969.
(30 U.S.c. 923)
All claims filed by insured workers for disability insurance benefits under Title 2 of the Social Security Act, as
amended; plus all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405(g))
All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social Security
Act, as amended. (42 U.S.c. 405(g))
All claims for supplemental security income payments based upon disability filed under Title 16 of the Social Security
Act, as amended.
All claims for retirement (old age) and survivors benefits under Title 2 of the Social Security Act, as amended. (42
U.S.c. (g))
CY-71 (05/08) CIVIL COVER SHEET Page 2 of2