o

IN SUPERIOR COURT
In
re:
AYMANABUAITA
Beit Sahour, Bethlehem, West
Bank
Palestine,

('

THE DISTRICT OF COLUMBIA

11
Division)

\fC

Plaintiff,

1n

versus

Civil Action Number:

COMPLAINT FOR DAMAGES

SACHA NOAM BARON COHEN, also knjjwn as

SACHA BARON COHEN
11766 Wilshire
Boulevard
Unit
Number
1610
Los Angeles, California
90025,

AND FOR INJUNCTIVE REUEF

and

DAVID MICHAEL LETTERMAN

193 Baxter
RoadSalem* New York
Noth
10560,
and

LAWRENCE CHARLES WENGROD,

also known
as
LARRY CHARLES
10571 Ottone
WayAngeles, California
Los
90077,
and

JONAH HILL FELDSTEIN

also known as JONAH HILL
2877 Motor
Avenue
Los Angeles, California
90064,
and

DAN MAZER
12-26 Lexington
Street WIF OLE
London
United
Kingdom,

JURY TRIAL DEMANDED

FILED
CIVIL AGTfOSS
BRANCH
APR 3 0 2010
SUPilOl COURT
OFTHE OlSOICTOFOOUiWA
WASHINGTON,
DC

e
and

MATTHEW JAY ROACH

6008 Topeka Dive
Tarzana, California 91356
and

NBC UNIVERSAL, INC., a

Delaware corporation, doing business as
"Universal Pictures" and "Universal Studies
Home Entertainment"
30 Rockefeller Plaza
New York, New York 10009
Telephone: (212) 757-5294,
serve: CT Corporation System
1015 Fifteenth Street, N.W.
Suite 1000
Washington, D.C. 20005,
and

CBS BROADCASTING* INC., a New York

Corporation
5 L West 52nd
StreetYork, New York 10019
New

Telephone: (212)975-4321,
serve: Corporation Service Company
1090 Vermont Avenue, N.W.
Washington, D.C. 20005,
and

WORLDWIDE PANTS, INCORPORATE^,

a New York corporation
1697 Broadway
New York, New York 10019
Telephone: (212) 975-5300,
serve: New York State Department of State
99 Washington Avenue
Suite 600
Albany, New York 12231
alternative service: David Michael Lettermanj qua
Chief Executive Officer tnereof
193 Baxter Road
Noth Salem, New York 10560,

and

GANNETT COMPANY, INC., a Delaware

Corporation, doing business as WUSA Television
7950 Jones Branch
Dive
McLean, Virginia
22107-0150(703)
Telephone:
854-6696,
serve: Craig A. Dubow, Chairman, President
.
CEO
7950 Jones Branch
Drive
McLean, Virginia
22107-0150,
and

BLOCKBUSTER; INC., a Delaware

Corporation
Renaissance
Tower
1201 Elm
Street Texas
Dallas,
75270
Telephone: (214)
854-4266,
serve: Prentice-Hall Corporation System,
Inc. 1090 Vermont Avenue,
N.W.
Washington,
DC.
20005,
Defendants.

COMPLAINT FOR DAMAi 1ES AND FOR INJUNCTIVE RELIEF

(JuryTrial Demanded)
COMES NOW, before this Honorable (lourt, your plaintiff in the above-encaptioned
cause,
AYMAN ABU AITA, by and through his und srsigned attorneys and counsellors, viz,,
Joseph
Peter Drennan and Sam W. Burgan, respectful ly, to lodge his Complaint for Damages
and for
Injunctive Relief, by showing unto this Honor ible Court as follows,
viz.:

PARTIES
I.

That your plaintiff, viz., AYMAN ABU Al TA, is a natural adult person, of
Palestinian

nationality, whom, at all times relevant herein, has been, and is presently, domiciled in
the village

of Beit Sahour, West Bank, in the teritory known as Palestine, whom, until recently, supported
his
wife and four children as a grocer; he is also a Board Member, as well as the Treasurer, of the
Holy
Land Trust, based in Bethlehem, a charitable organization committed to promoting peace
and
reconciliation among Israelis and Palestinians, of all religious faiths, and he is a Chrisian whom
is a
member and congregant of the Greek Orthodqx
Church;
II.
That, upon information and belief, your defendant known as SACHA NOAM
BARON
COHEN, also known as SACHA BARON COHEN (hereinafter referenced qua "COHEN"), is
a
natural adult person, who is a Bitish Subject,domiciled in the State of California, whom is
employed
as, inter alia, an actor, comedian and writer, whom was featured in, inter alia, the "Btino" Movie,
and
it also bears mention herein that COHEN also| was a producer of the "Brtjno"
Movie

m.
That, upon information and belief, your defendant known as DAVID
MICHAEL
LETTERMAN (hereinater referenced qua "L ETTERMAN"), is a natural adult person, domiciled
in
the State of New York, residing at 193 BaxterRoad, North Salem, New York 10560,
whom is
employed as, inter alia, a comedian and televi sion host, who hosts, inter alia, *'Late Show With
David
Letterman," at the Ed Sullivan Theater, in New York City, which show is broadcast over the
CBS
Television Network, and, as more fully descibed hereinater, said defendant hosted The Late
Show
With David Lettennan on 7 July
2009;
IV.
That, upon information and belief, your dt fendant known as LARRY CHARLES WENGROD,
also
known as LARRY CHARLES (hereinafter reerenced qua "CHARLES") is a natural adult person,
and

citizen of the United States of America, whorris believed to be domiciled in the State of
California, is
employed as a witer, director and producer, aid was the director of, inter alia, the "BrUno"
Movie;

V.

That, upon information and belief, your defendant known as JONAH HILL FELDSTEIN,
also
known as JONAH HILL (hereinafter referenced qua "HILL1') is a natural adult person,
and
citizen of the United States of Ameica, whom is believed to be domiciled in the State of California,
is
employed as a witer, director and producer, a^id was a co-producer of, inter alia, the "Biino"
Movie;

VI.
That, upon information and belief, your defendant known as DAN MAZER (hereinafter
referenced
qua "MAZER") is a natural adult person, and British subject, whom is believed to be domiciled
in
London, is employed as a witer, diector and producer, and was a co-producer of, inter alia,
the
14BrUno"
Movie;

Vll.
That, upon information and belief, your defendant known as MATTHEW JAY ROACH,
also
known as JAY ROACH (hereinater reference 1 qua "ROACH") is a natural adult person,
and
citizen of the United States of Ameica, whom is believed to be domiciled in the State of California,
is
employed as a writer, director and producer, and was a co-producer of, inter alia, the "BrUno'*
Movie;

VIII.
That, upon information and belief, your defendant known as NBC UNIVERSAL, INC.
(hereinafter
referenced qua "UNIVERSAL"), is a dejure < orporate personality, organized under the laws of
the
State of Delaware, and having its pincipal place of business at 30 Rockefeller Plaza, New York,
New
York 10009; upon futher information and belief, said corporate defendant is one of the world's
larger
media and entertainment companies, and is involved, inter aliay in the business of
distibuting
cinematic ilms, through its "Universal Pictuw s" division, as well as in the distribution and
marketing
for retail to the public of DVD format recordir gs of cinematic works, through its "Universal
Studios

Home Entertainment" business; upon further ilformation and belief, UNIVERSAL was
and is the
domestic and worldwide distibutor and marks ter of both the cinematic and DVD versions of
the

"BtJno" Movie; UNIVERSAL, thus, acted, t publish and republish the "BrUno" Movie at
several
movie theaters in the Distict of Columbia, well as throughout the United States, and around
the
as
world
as well, at the times
and has, likewise, distibuted and marketed
specified hereinaft
the
"Briino" Movie in numerous retail establishm snts in the Distict of Columbia, and elsewhere, at
the
times speciied hereinafter; in addition, UNIVERSAL continues to market and distribute the
"Btlno"
Movie through various media, in the Distiict of Columbia, inter loci, including, but not limited to:
Best
Buy (DVD); Distict Cablevision on dema id movies; Dish Network ; Netflicks ;
Veizon FIOS ; Redbox (DVD); and Target <S>
(DVD);
DC..

That, upon information and belief, your defendant known as CBS BROADCASTING,
INC.
(hereinater refeenced qua "CBS"), is a dejure corporate personality, organized under the laws of
the

State of Delaware, and having its pincipal pice of business at 51 West 52nd Street, New
York, New
York 10019; upon further information and belief, said corporate defendant is a major
Ameican
television broadcasting network which distrib tes for broadcast on its numerous television
station
affiliates across the Stales, including, inter alii, WUSA Television, Channel 9, in Washington,
D.C., a
full compliment of regular and special events programming, including, inter alia, "The Late
Show
With David
Letterman";
X.
That, upon information and belief, your dc fendant known as WORLDWIDE PANTS,
INC.
(hereinafter referenced qua "WORLDWIDE" I, is a dejure corporate personality, organized under
the
laws of the State of Delaware, and having its Pincipal place of business at 1697 Broadway, New
York,
New York 10019; upon further information and belief, at ail times relevant herein, said
corporate
defendant is the producer of "The Late Show with David
Letterman";

o
XL

That, upon information and belief, your defendant known as GANNETT COMPANY,
INC.
("WUSA"), is a dejure corporate
organized under the laws of the State of Delaware,
personality,
and
Jones Branch Drive, McLean, Virginia 22107-0150;
having its pincipal place of business at
upon
7950
further information and belief, said
defendant is a major newspaper and television
corporate
media
company in the United States, which owns, ir ter alia, WUSA Television, Channel 9, in
Washington,
D.C., the longest-tenured afiliate of the CBSTelevision Network; upon further information and
belief,
WUSA broadcast, on a customary taped delaj basis, inter alia, the unexpurgated 7 July 2009
edition of
"The Late Show With David
Letterman";

XH
That, upon information and belief, your defendant known as BLOCKBUSTER, INC.
(hereinafter
referenced qua "BLOCKBUSTER"), is a dejure corporate personality, organized under the laws of
the
State of Delaware, and having its principal place of business in the State of Texas, at
Renaissance
upon further information and belief, said defendant is
Tower, 1201 Elm Street, Dallas, Texas
an
75270;
Ameican-based chain of DVD, Blu-ray Disk and video game rental stores, with more than
9,000
stores in 25 counties worldwide, including two stores situate in the Distict of Columbia, viz.,
one
outlet located at 1805 Columbia Road, N.W.,Washington, D.C. 20009, and a second outlet
located at
410 Eighth Street, S.E., Washington, D.C. 20()03, which stores carry, inter alia, inter alia,
the
"Briino" Movie;

JURISDICTION AND VENUE

XIII.
That this Honorable Court has juisdictior over the instant matter under the provisions of Title
1I,
921, of the Distict of Columbia Code of Geeral and Permanent Laws (2001 ed.); this
Honorable
Court may exercise, properly, in personam juisdiction over each of your within-named
defendants,
pursuant to the enabling provisions of Title 1:, 423 (a) of the Distict of Columbia Code of
General

and Permanent Laws (2001 ed.) (the "Long-Arm Statute"), inasmuch as, inter alia, the subject
matter
of the instant litigation, viz., certain calumnious accusations implicating your plaintiff were
contained
in certain discrete media, viz., the cinematic ard DVD versions of the "Bruno" Movie, and the
7 July
2009, broadcast of 'The Late Show With David Letterman," were all deliberately and
intentionally
published and or republished, and sold and rer ted to the public, and continue to be so
distributed in,
inter loci, the Distict of Columbia, by your d fendants, each of them, acting, vaiously, separately,
and
or in
concert;

FACTl AL AVERMENTS
(inducement)
XIV.
That, in accordance with 219 of
gration and Nationality Act, as amended,
the
the
Secretary of State has designated the "Al-Aqsa Martyrs Bigade" as a Foreign
Terrorist
Organization (hereinafter designated qua
"FTp")1;
XV.
That, for the purposes of identifying a FTC K inter alia, the United States Code (Title
22,
Chapter 38, Paragraph 2656f(d)) defines "terroism" as "... premeditated, politically
motivated
violence perpetrated against noncombatant targets by subnational groups or clandestine
agents";

XVI.
That 18 U.S.C., 2331 deines "terroism" as:
". , activities that involve violent... or life-threatening acts ... that are a violation of the criminal
laws of the United States or of any State and . .. appear to be intended (i.) to intimidate or
coerce population;
a
civilian
(ii.) to influence the policy of a government by intimidation or coercion; or (iii.)
to
affect the conduct of a government by mass destruction, assassination or
";
kidnapping

See: Curent List of Foeign Terrorist Organizations posted by the Secretary of Stale's Coordinator for Counterterroism, on the United States Department of State Inte met website:
http://www.5tate.gOv/s/ct/rts/other/des/123Q85.htm

XVII.
That, at all time relevant herein, alien representatives and members of a designated
FTO are
inadmissible to the United States, and are, in certain circumstances, removable from the
United
States2
;

xvm.
That, in addition to its having been
ited by, inter alia, The Government of the United
desig
States
of Ameica as a terroist organization, as referenced supra, the Al-Aqsa Martyrs Brigade is
generally
and widely recognized throughout the world, ind, perforce, in the Middle East, as a notoious
terrorist

group, culpable in the wanton slaughter of dozens of innocent people, and in the targeted
assassination<s
of many
others;

XIX.
That* as adverted to above, your plaintiff is a peace-loving person who abhors violence, and,
pior
to the publication and republication of the cal imnies complained of herein, enjoyed a good
reputation

for honesty and a peaceable nature throughouhis community in Bethlehem, in the

District of
Columbia, as well as amongst his
numerous
United
States;

relatives, friends and associates throughout the rest of

the

XX.
That, on or about 30 June 2009, the "Brunt" Movie premiered in
Hollywood;

XXI.
COHEN appeared with, inter alios, LETTERMAN, on
That, as adverted to supra, on 7 July
2009
'The Late Show With David Letterman," whi ;h show was broadcast, on a tape-delayed basis,
over
CBS's eponymous broadcasting television network, including, inter alia, over
WUSATelevision,
Channel 9, which broadcast, upon informatioi and belief, reached thousands of television
viewers in
the Distict of Columbia, and millions more tiLroughout the rest of the United States, through other
CBS
See: 8 U.S.C., 1182 (a) (3) (B) (i) (IV)-(V) 1227.

affiliates;

XXII.
That, in the course of his aforesaid appear* nee with LETTERMAN, COHEN went to great
lengths
to portray falsely your plaintiff as a "terrorist jjroup leader al-aqsa martyrs brigade {sic.)*",
and
suggested that he learned such putative association through a contact at the "C.I.A.",
presumably, the
United States of Ameica's Central Intelligence
Agency";

xxin.
That, although couched in some banter, a (Jiscernment of the warp and woof of the
COHEN
mpression that each defendant was
LETTERMAN dialog gives the
desirous of
unmistakable
conveying the message to the audience that your plaintiff was, indeed, a "terroist , who is a
group
leader of the Al-Aqsa Martyrs Bigade, as evinced by the following excerpts from the colloquy
between
COHEN & LETTERMAN, set forth, haec verba,
thusly:
BY COHEN: You know, when we were making this ilm, we wanted it to be better than Borat and
we
thought :what could people see that they've never seen before on ilm? And we thought one
thing
would be a comedian interviewing a terroist, >o, which I think has never been done before for
good and so we showed the scipt you know the outline of the script to the studio and they said:
reason,
'oh,
this is great, and who's going to play the terrorist?' And we said: 'no, we're going to ind a real
terrorist.
Now, it's not that easy to find an actual terroist. In fact, your government has been looking for one
for
about nine
years.

BY LETTERMAN: Exactly ight!

BY COHEN: There's no Craig's List in Beirut for example. So we called up a contact we had at
the
C.I.A. and said: 'Can you help us? We're lookiig to ind a
terroist'.
BY LETTERMAN: Bruno has a contact at the
CJ.A.?
BY COHEN: Bruno doesn't, but I knew somebody who did. And the guy at the C.I.A. said, you
know:
We've got a lot of names of terroists but we r, ave almost no addresses.' And, so, eventually, after
a few we found somebody who actually live d in a town that had a terrorist from a pretty nasty
months,
group
called the Al-Aqsa Martyrs Bigade, who are * ind of the number one suicide bombers out
there, if
3 Said phrase appeared in a caption beneath the portrayal of your plaintiff in an excerpt from the "Briino" Movie which
was published on "The Late Show With David Lettejrman" in the latter course of the subject, on-air, interview of
COHEN by LETTERMAN.

10

you're looking for them. And he said: 'Yeah, y >u know, there is a terroist who lives in my town';
so
I 'Great! You know: Can we interview him? But I'm a little bit scared about reprisal attacks from
said:
the people in the you know in your city.1 And he said: 'Don't worry, you know, everybody loves
other
you,
we love the Ali G Show!* So, so the next thing was 1 thought I needed some secuity to get
to the because it (sic.) was in the West Bank, the guy picks this secret location, so we called
terroist
around
some secuity irms. Everybody said: 'no way!' And, eventually, I found one guy who was
an
Englishman
who had done the Enrique Iglesia; Hero Tour
(sic).
BY LETTERMAN: You gotta go where you f otta go.
Wow!
BY COHEN: You know, his main job had been protecting Enrique from flying underwear (sic).
You you know, I knew, if it came to it, this guy would take a bra for me. So we get there, and I
know,
said:
'Alight, listen! Tm a little bit scared that the tt rroist and his body guards' gonna be armed,
so, if armed, let's have a code word. So, if th sir armed, say that it's going to be hot weather,
they're
and, if not armed, there's no guns, say it's going to be cold.' So we end up at this secet
they're
location.
The in with his body guard. They've been checked by my body guard; my body guard
terroist comes
comes
in and I said: 'So what's the weather going to be?1, and he says: 'Un, well, 1 think it's going to be
cold
weather
but there's a chance it could be quite warm and it might even be boiling hot!' At which
point,
the terroist said: 'No, no, no. It is not cold. It ijs warm'. And then I realize I'm pretty sure that
my
terroist either did or did not have a gun on
hi
BY LETTERMAN: You're certainly getting ybur money's worth
there.
BY COHEN: And then, my body guard says: Ya, you're right you know. It is quite warm out here.
It's of much, much warmer out here. It's kind of much, much warmer than North England', at
kind
which
point, I realized that my body guard had forgo ten about our role
play.
BY LETTERMAN: He was talking about
theweather.
BY COHEN: I was discussing the weather wi :h a
terroist.
BY LETTERMAN: Now, will these guys eventually see the ilm? Did you invite them to the
premiere,
or?

BY COHEN: I pray to God not!

(emphasis
added
Then, as adverted to supra, the television co 'erage segued from the aforesaid
COHEN LETTERMAN dialogue to the aiing of an exc erpt from the "Brtno" Movie, which depicted your
plaintiff being interviewed by COHEN, in whi:h excerpt, significantly, the following caption
appeared,
under your plaintiffs visage, when your plaint: ff was shown on screen, viz.: 'errorist group leader

11

al-aqsa martyrs brigade9'; the COHEN - LETTERMAN interview then draws to a close, with
LETTERMAN, essentially, predicting that tht "BrUno" Movie would be a "blockbuster (sic.)"
like
"Borat", COHENs last cinematic
release;
XXIV.
That, as adverted to supra, the "Bruno" Movie was released nationwide, in the United States,
on 10
July 2009, after having been released the day t>efore in Australia and New Zealand;
subsequently, upon
information and belief, the "BrUno" Movie has been released in many other counties around the
world,
including, inter loci, Israel, where it was shown with Hebrew
subtitles;
XXV.
BrUno" Movie was released nationwide, in the
That, on or about 17 November 2009,
United
thei
States, on DVD recording, for sale and rental to the general public, both on-line and
through
innumerable retail outlets, including scores of stores in the Distict of Columbia, including, inter
alia,
the Distict of Columbia BLOCKBUSTER oi tlets eferenced supra;

XXVI.
That, on even date, id est, 17 November 2Q09, COHEN and CHARLES appeared as guests on
Terry
Gross' respected, high brow radio show on Ni tional Public Radio ("NPR"). "Fresh Air'\ to discuss
and
promote the "BrUno" Movie; said interview was aied nationwide on NPR affiliates, including,
inter
alia, locally, on WAMU and WHUR; although the scene from the "Bruno" Movie in which your

plaintif was depicted was not explicitly mentoned, COHEN and CHARLES waxed expansively
about
how the "BrUno" Movie represented a new gene of comedy, in which the comedic actor is
placed is
real, dangerous situations, in which he (the ccjmedian) thereupon deigns to make some sort of
comic
effect;

XXVII.
That the dusi jacket encasing the retail DVD of the "Biino" Movie explicitly mentions "terrorists",
with said term deigned to reference your plair tiff and the latter's ictional bodyguard; upon
information
12

and belief, all packaging and promotional mateials respecting the "BrUno" Movie were designed
and
or approved by
UNIVERSAL;

XXVIII.
That, contrary to the false insinuations misrepresentations contained in both the
"BrUno"
and
Movie, the "BrUno" Movie DVD and the aforesaid COHEN - LETTERMAN interview, at no time
was COHEN in any danger, whatsoever, when he interviewed your plaintiff, nor was the interview
at a
"secret location"; in fact, upon information and belief, the interview took place at a spot selected
by
COHEN, CHARLES, HILL, MAZER and ROACH, viz., the Everest Hotel, which, although located
on
the West Bank, in Beit Jala, is in an area designated by the Israeli military forces as "ZONE 'C"\
which
is under full Israeli military control; it is also noteworthy that the Everest Hotel is flanked by an
Israeli
police academy and an Israeli military
base;

XXIX.
That, upon information and belief, your de fendants, each of them, evinced either actual
malice or
else a reckless disegard for the truth, in rcspejct of their respective actions vis-d-vis your
plaintiff;

XXX.
That the subject interview of your plaintiff by COHEN took place some months prior to the
release
to the the "BrUno" Movie, under a palpably false pretense, viz., that COHEN was a
German
"journalist", whom was desirous of interview ng your plaintiff about the plight of the
Palestinian
people;

XXXI.
That, upon information and belief. COHEN, CHARLES, HILL, MAZER and ROACH schemed
to
find an unwitting person (read: your plaintiff)to participate in the subject interview at the
Everest
Hotel, by having a currently unknown emissaj-y of COHEN, CHARLES, HILL, MAZER and
ROACH
contact a representative of the Holy Land Truit, in Bethlehem, seeking a interview subject who
was: i.)
a Christian; ii.) who had been administratively detained by Israel at some point; and iii.) who
was a
13

member of the Fatah political

party;

XXXII.
HILL, MAZER and ROACH, and their unknown
That such efforts by COHEN,
CHARLES
confederates, ultimately resulted in your plaintiffs traveling to the Everest Hotel, for what he
thought
would be a simple interview with some Germ m journalist who was interested in learning about
his
peaceful activism with the Palestinian and Ismeli peoples; as an aside, it bears mention that, at no
time
pior to the subject interview did your plaintif suspect anything untoward especting the
subject
interview equest, inasmuch as the Everest Hotel has long been a well known and popular
gatheing
place for Palestinian and Israeli peace
activists;

XXXIII.
That, upon information and belief, when he arrived at the Everest Hotel for his subject
interview,
your plaintiff was met by an unidentified confederate of COHEN and CHARLES, who led him to
a
room upstairs in the Hotel, to meet "the German journalist" for the
interview;

xxxrv.
That, upon information and belief, unbekriownst to your plaintiff, confederates of
COHEN,
CHARLES, HILL, MAZER and ROACH had rented out an entire floor of the Everest Hotel in
advance
of the subject interview, and had had contractors configure the interview room with a false wall
and a
double-mirror, where CHARLES could surreptitiously monitor the subject
interview;

XXXV.
That, at no time pior to the commencemeht of the subject interview, or else ater the interview,
was

your plaintiff made aware that excerpts of theinterview would be featured in the
"BrUno" Movie;
XXXVI.
That, at no time pior to the subject interview or else after the conclusion of the interview, did
either
CHARLES or COHEN or any of their confederates disclose to your plaintiff that he would be
featured
in any movie, much less the "BrUno"
Movie;
14

XXXVII.
That, at no time either pior to the subject |interview, or ater the interview, did CHARLES
or
COHEN, or, for that matter, anyone else, pres ;nt your plaintiff with any sort of release or
request for
permission to utilize your plaintiffs identity, or else his image, in any commercial activity, enterpise
or
production;

(Colloquium)

XXXVIII.
That, as adverted to above, your plaintif ^as identiied explicitly in the "BrUno" Movie as

'terroist group leader al-aqsa martyrs brigade", under a bold display of his full name, viz.:

Ayman Abu Aita";

xxxrx.
That, upon information and belief, the excjerpt from the "BrUno" Movie in which your plaintif
was
depicted, when viewed by the public on television sets and video monitors, through the WUSA
outlet,
inter alia, included the CBS trademarked "ey?" logo, connoting the impimatur of CBS
News;

XL.
That the depiction of your plaintiff in the JBrUno" Movie shows a full-facial view, such that there
is
no mistaking whom is being characterized as i "terroist" in the "BrUno"
Movie;

XLI.
That, upon information and belief, your plaintiffs likeness has been misappropriated and
used by
COHEN, CHARLES, HILL, MAZER, ROACH, LETTERMAN, CHARLES, UNIVERSAL, CBS,
WORLDWIDE, and WUSA, inter alios, to p 'omote and market the "Bruno" Movie and "The Late

Show With David Letterman", as exemplifiedby, inter alia, an Internet viral

video-marketing
campaign, including the posting of several cii;>s of the subject interview of your plaintiff by
COHEN,
excerpted from the "BrUno" Movie, on the Yo|i Tube video shaing
website
15

(e.^.:http://www.youtube.com/watch?v=Qk2o:e2kjT8&feature=fvw ), which marketing method was

pioneered by COHEN in his earlier "Boraf movie4, and in the promotional language on the DVD

jacket for the "Biino" Movie, which reference s, inter alia, "terroists";

XLIL
That, upon further information and belief, UNIVERSAL is the holder of the U.S. Copyright for the
"BrUno" Movie, and UNIVERSAL has approve d and condoned the viral publication and re-publication of
the "Biino" Movie on YouTube.com and other social media over the Internet, for marketing purposes.
with particular emphasis on the publication andre-publication of the subject calumnious scene from the

"BrUno" Movie, even ater it had been noticed by your plaintiff, per the iling of the subject antecedent
distict court litigation, on 2 December 2009; th js, there can be not gainsaying that UNIVERSAL was not

merely the distibutor of the "BrUno" Movie, b it, rather, was intimately involved with the publication and
successive e-publication of the subject calumn es against your plaintiff; moeover, thee can be no

denying UNIVERSAL's key role in the continu ng distibution and promotion of the subject calumnies
against your plaintiff as there is no indication that it has deigned to asserting its prerogative of removing

the subject calumnious copyighted video from YouTube and other Internet social media; ditto, for CBS,

LETTERMAN and WORLDWDE, as regards the video excerpts from the aforesaid COHEN TTERMAN interview0;

See: Stowe, Debbie & Paul Stump, "Who is Boral? The Unauthoized Biography of Sacha Boron Cohen", ((Candour
Limited, Denmark (2007)), at p. 149.
See, e.g.: "BrunoTerroist (sic.) interview": hto://www^qutubefcom/watch?v=ElTgT35fZWs .It is noteworthy that said
video posting alone, one of dozens known to rcmair extant on the 1 ntemet, has had some 255,573 vie wings as of
29 2010. Upon information and belief, the pheno nenon known as viral video has caused a geometic multiplication
April
of publications of such calumnious video.
See, e.g.: "The Late Show With David Letterman -Sacha Baron Cohen Interviews a Terrorist":
htfp://wvvw.voultibe.com/waich?v==Ok2oce2kfT8Atature^fvw It is also noteworthy that, upon further information and
belief, like, the "BrunoTerrorist (sic.) interview", sdid latter Letterman - Cohen interview video has had some
3,724,277, vie wings, as of 29 Apil 2010, and has, through the viral video phenomenon, resulted in a geometric
multiplication of millions of moe vie wings over thej Internet.

16

xun.
That, upon information and belief, COHEN CHARLES, HILL, LETTERMAN. MAZER, ROACH,

CBS, WORLDWDE and UNIVERSAL, inter [tlios, schemed to use the insidious publication and republication of the defamation of your plaintiff z s the center piece of their strategy to market the "BrUno"
Movie, and, that said defendants continue to in< ulge in such promotion by defamation strategy, all to the

detriment of your plaintiff;

[Innuendo)

XLIY
That, upon information and belief, the confluence of the foregoing enumerated circumstances,

foreseeably and deliberately, were intended toand, in fact, did, brand falsely your plaintiff, a
peace
activist, family man and prominent businessm in, as a "terroist", and that, upon further information and
belief, a substantial proportion of people in yo jr plaintiffs hometown, as well as people throughout the

world, including, inter loci, the District of Columbia, believe your plaintiff to be a terroist and massmurderer, based solely upon the malicious depiction of him as a "terroist", both in the "Briino"
Movie, as well as on the David Letterman Shpw;

XLV.
That the within-described accusations, insinuations and representations that your plaintiff is, or ever
was, associated with the notorious Al-Aqsa Mkrtyrs Bigade, or, for that matter, any other terroist
activity or cause, is utterly false and untrue, an d your defendants, each of them, had every eason to

believe or know that, yet slandered your plaimiff anywise;

(Harm Susained by Your Plaintif)

XLVI.
That the calumnies descibed hereinbefore have caused your plaintiff to suffer extensive damage

and loss, including, but not limited to, the following, viz.: death threats; shame; loss of reputation; loss
17

of effectiveness as a community organizer an< conciliator; depression and anxiety; loss of business to

his family market; and fear for the well-being and safety of his wife, children, and his relatives, both on
the West Bank, the District of Columbia, and, elsewhere in the United States, and, indeed, throughout

the world;

XLVn.
That, in addition to the above-referenced range of harm to your plaintiff, the misappropiation of

your plaintiffs likeness in the "Biino" Movie, 4The Late Show With David Letterman", and in
promotional mateials respecting such productions, has intruded upon your plaintiffs pivate life, and has
falsely associated your plaintiff with a scurrilous and scandalous movie, causing him great emotional
distress, depression and shame, to say nothing of loss of reputation and loss of business;

xlviii.
That, in addition, your plaintiff has incurred considerable attorneys' fees and travel expenses as he
has been obliged to travel to the United States to vindicate his good name and, concomitantly, to
salvage his reputation;

(Wrongful C ain by Your Defendants)

XLDC.
That, although it bears mention that, at thi s stage, pre-discovery, your plaintiff is not in a position

to posit the ill-gotten gains realized by your corporate and individual defendants, upon information and
belief, such gains were, indeed, substantial, ar d, as a benchmark in such regard, upon further

informaion and belief, the current box ofice take rom the "Biino" Movie, exclusive of DVD sales, is
approaching the sum of Two Hundred Million IJollais ($200,000,000);

18

L.
That it bears further mention that, on 2 Dec :mber 2009, your plaintiff iled a Complaint for Damages

andlnjuncnve Relief, for defamation, against COHEN, LETTERMAN, UNIVERSAL. WORLDWIDE,

CBS, GANNETT and CHARLES7, in the Uni tidStates Distict Court for the District of Columbia, qua

Civil Action No. 1:09-cv-02285-RWR, thereby puting said defendants on notice of your plaintiffs claims
and of your plaintiffs demand that the subject calumnious mateial be withdrawn from distribution and
sale, yet, notwithstanding same, your defendant have continued to promote and market the "Biino"
Movie, thereby exacerbating the harm to your plaintiff and putting paid to any notion that any of your said

defendants were unaware of the defamatory nature of the "Biino" Movie, as regards your plaintiff;

WRONGS 0 F THE DEFENDANTS

FIRST COUNT
(UBELAND SLANDER Published on 7 My 2009 Against COHEN, LETTERMAN, CHARLES,
HILL, MAZER, ROACH, UNIVERSAL, CBS, WORLDWIDE, and GANNETT)

LI.
That your plaintiff hereby incorporates by reference heein, as if set out in full, each and every one
of the foregoing averments contained in this ('omplainf.

It should be noted that your plaintiff added BLOCKBUSTER as a defendant in the district court action per the filing of
an Amended Complaint on 5 February 2010. Ultimately, UNIVERSAL, LETTERMAN, WORLDWIDE, CBS and
GANNETT were served with process in e spec I of jhc abovc-rcfcrcnced United States Distict Court action. On 4 March
2010, UNIVERSAL moved to dismiss said distict court action, challenging jurisdiction under diversity of citizenship.
Subsequently, on 1 Apil 2010, LETTERMAN, WORLDWIDE, CBS and GANNETT joined in UNlVERSALs Motion
to Dismiss. Essentially, said defendants have contended that diversity juisdiction cannot be maintained because of
the
fact that your plaintiff and COHEN arc non-U.S. Cozens, even though COHEN is believed to reside in Los Angeles,
and, concomJtanUy, because your "[pjlaintiff. as a Palestinian national, does not qualify as a 'citizen [] or subject of a
foreign nation1 who can invoke alienage jurisdiction because Palestine is not recognized by the United
States
government."
(Memorandum of Poi nts and Authoities in Support of Motion of (UNIVERSAL) to Dismiss the First
Amended Complaint" I Document 6 @ p.3] Accordingly, your plaintiff did signify to the distict court, on 6 Apil 2010,
that he docs not oppose the motion dismiss and that your plaintiff intended to recommence his claims before
this
Honorable Court - hence the instant action. It should also be noted that, inter alia, the instant action adds HILL,
MAZER and ROACH, co-producers, with COHEN of the "BrUno" Movie, as parties defendant.
19

LIL
That the depictions of your plaintiff in the "Biino" Movie and on "The Late Show With David
Letterman*', as a "terroist" were intended to, and in fact did, brand falsely your plaintif as a
terroist
and criminal, causing the harm complained of
herein;
SECOND COUNT
(UBELAND SLANDER Published on 10 July 2009 Against COHEN, CHARLES, HILL, MAZER,
ROACH, and UNIVERSAL)

LIIL
That your plaintiff hereby incorporates by reference herein, as if set out in full, each and every
one
of the foregoing averments contained in this
tomplainv.

LIV
cinematic release of the "Biino" Movie as a "terrorist"
That the depictions of your plaintiff in
the
were intended to, and in fact did, brand falsely your plaintiff as a terorist and criminal, causing
the
harm complained of
herein;

THIRD COUNT
(UBELAND SLANDER Published on IX November 2009Against COHEN, CHARLES, HILL,
MAZER, ROACH, UNIVERSAL and BLOCKBUSTER)
LV.

That your plaintiff hereby incorporates reference herein, as if set out in full, each and every
one
by
of the foregoing averments contained in this
Complaint;
LV1.

DVD release of the "Bruno" Movie as a "terroist" were

That the depictions of your plaintiff in
the
intended to, and in fact did, brand falsely you if plaintiff as a terrorist and criminal, causing the
harm
complained of
herein;

20

FO URTH COUNT
(TORTOUS MISAPPROPRIATION OF NAME OR LIKENESS (Restatement of the Law, Second,
Torts, 652) Against All
Defendants)
LVII.
That your plaintiff hereby incorporates reference herein, as if set out in full, each and every
by
one
of the foregoing averments contained in this
Complaint;

LVIII.
That the misappropriation of your plaintiffs name and likeness in the "Biino" Movie, "The
Late
Show With David Letterman", and in accomp uiying and ancillary promotional images, videos
and
materials, was without your plaintiffs conseni or permission, and contrary to his intent, and has
led.
inter alia, to your plaintiffs name and likene:s falsely being associated with the promotion
and
production of a scurrilous and scandalous mo1 ie, causing, actually, directly and proximately,
your
plaintif to suffer the harm complained of herpin, and resulting in unjust enrichment to
your
defendants;

FiFTH COUNT
(UBELAND SLANDER Published on, inter tempus, on 30 April 2010, Against COHEN,
LETTERMAN, CHARLES, HILL, MAZER, ROACH, UNIVERSAL, CBS, and WORLDWIDE)
LVIV.
That your plaintiff hereby incorporates reference herein, as if set out in full, each and every
by
one
of the foregoing averments contained in this
Complaint;
LVV.
That the continuing publication and repub ication of the Internet viral video known as the
"Bruno
Terroist (sic.) interview ", falsely depicting yaur plaintiff as a "terrorist", as described hereinbefoe,
is
intended to, and, in fact, has, defamed your phintiff, causing him to suffer signiicant
harm;
8 See, e.g.: "Bruno Terroist (sic.) interview": http://uww.voutube.com/watch?v=EITg"nSf2Ws
21

SIXTH COUNT
(UBELAND SLANDER Published on, intertempus, on 30 April 2010, Against COHEN,
LETTERMAN, CHARLES, HILL, MAZIR, ROACH, UNIVERSAL, CBS, and WORLDWIDE)
LVVI.
That your plaintiff hereby incorporates reference herein, as if set out in full, each and every
by
one
of the foregoing averments contained in this
Complaint;

LVVH
That the continuing publication and repub|lication of the Internet viral video known as the
"The
Late Show With David Letterman - Sacha Bafron Cohen Interviews a Terroist9", falsely depicting
your
plaintif as a "terroist", as descibed hereinbt foe, is intended to, and, in fact, has, defamed
your
plaintif, causing him to sufer significant har ti;

PRAYER AND AD DAMN A

WHEREFORE, and for the foregoing reasons, your plaintiff ever
prays:
(i.) That, in consideration of a finding of liability in respect of his FIRST COUNT, he be
awarded
compensatory damages against all liable defe idants, jointly and severally, in an amount
to be
determined by the tier of fact or else the sumof Ten Million Dollars (S 10,000.000), and
exemplary
damages in the sum of One Hundred Million Dollars ($100,000,000) against each liable
defendant;
(ii.) That, in consideration of a inding of liability in respect of his SECOND COUNT, he
be
awarded compensatory damages against all Ii; ible defendants, jointly and severally, in an amount
to be
determined by the tier of fact or else the
of Ten Million Dollars ($10,000,000), and
sum
exemplary
damages in the sum of One Hundred Million dollars ($ 100,000,000) against each liable
defendant;
9 See, e.g.: 'The Lale Show With David Letterman - Sacha Baron Cohen Interviews a Terroist
htip:;/wwwvomube.com/waich?v=Qk2oee2kiT8& eature^fvw.

22

*+

(iii.) That, in consideration of a finding liability in respect of his THIRD COUNT, he be

awarded
of
compensatory damages against all liable defendants, jointly and severally, in an amount
to be
determined by the tier of fact or else the sum of Ten Million Dollars ($10*000,000), and
exemplary
damages in the sum of One Hunded Million Dollars ($100,000,000) against each liable
defendant;
(iv.) That, in consideration of a finding of liability in respect of his FOURTH COUNT, he
be
awarded compensatory damages against all liable defendants, jointly and severally, in an amount
to be

determined by the tier of fact or else the sumof Ten Million Dollars ($10,000,000), and
exemplary
damages in the sum of One Hundred Million 1 dollars ($100,000,000) against each liable
defendant;
(v.) That, in consideration of a finding of liability in respect of his FIFTH COUNT, he be
awarded
compensatory damages against all liable defendants, jointly and severally, in an amount
to be

determined by the trier of fact or else the sumof Ten Million Dollars ($10,000,000), and
exemplary
damages in the sum of One Hundred Million Dollars ($100,000,000) against each liable
defendant;
(vi.) That, in consideration of a finding oj liability in espect of his SIXTH COUNT, he be awarded
compensatory damages against all liable defendants, jointly and severally, in an amount
to be

determined by the tier of fact or else the sumof Ten Million Dollars ($10,000,000),
and exemplary
damages in the sum of One Hundred Million Dollars ($100,000,000) against each liable
defendant;
(viL) That your defendants be enjoined, both pendente lite and permanently, to withdraw
the

"Biino" Movie from commercial distibutionby whatever

means;
(viii.) That this Honorable Court impress u constructive trust on all revenues eceived or deived
by

your defendants as a result of the commercialdistibution of the "Biino" Movie and

appurtenant
usages of your plaintiffs name and likeness t r commercial
proit;
(vix.) That your plaintiff be awarded reasonable attorneys' fees with costs to follow;
and
c

(x.) That your plaintiff receive such otherand further relief against your
defendants as this
Honorable Court may deem just and properin.der the existent
circumstances.
23

Dated: 30 Apil 2010, at Alexandia, Virginia.

Res

fully subrni

* //Hmm>^
OSEPJf PETER DRENNAN
istict of Columbia Unified
ar No. 358196
18 North Lee Street

rhird Floor
\Jexandia, Virginia 22314
Telephone: (703) 519-3773
Telecopier: (703) 5484399
\l-Mail: Josephiosephpeterdrer|nan.com

SAM W. BURG
Distict of Colu]

Unified

Bar No. 4054;

5673 Columbia Pike, Suite 201
Falls Church. Virginia 22041
Telephone: (703) 575-8810
Telecopier: (703) 575-8054
E-Mail: sburgan @ BurganLaw.com

HATEM ABO AHMAD

Aaronsohn Sher Aboulafta, Amoday & Co., Law Ofices
21 Herzog Steet
Jerusalem, ISRAEL 92387
Telephone: (972-2) 5618677
Telecopier: (972-2) 5618678
E-Mail: [email protected]
Attorneys and Counsellors, in Praesenti, for Plaintiffs

24

DEMAND FO I TRIAL BY PETIT JURY

Dear Madam
Clerk:
Pursuant to Amendment VII of the Constitution of the United States of Ameica, and
the
corresponding provisions contained in SCR-Civil Rule 38 (b), your plaintiff hereby and
heewith
demands a tial by a petit jury of all disputed factual issues as well as on issues related to
monetary
relief.

Respecfully
submitted

/ltt*#3
OSEP
TER DRENNAN
Distict of Columbia Uniied
Bar No.
358196
218 North Lee
StreetFloor
Third
Alexandia, Virginia
22314
Telephone: (703)
519-3773 (703)
Telecopier:
548-4399
E-Mail:
[email protected]

25

CA Form 1

Superior Court of the District of Columbia

civil division
500 Indiana Avtnue, N,W.f Room JM-170
Washington, D.C. 20001 Telephone: 879-1133

TA

(WHAM ABU PiT

*\ ^ ** o r\ r> i*s

Plaintif
vs.

-10

Civil Action No.

f>LOCKBuS-ri^,%
Defendant

SUMMONS

To the above named

Defendant:

You are hereby summoned and required to serve an Answer to the attached Complaint, either
personally or through an attorney, within twenty (20) days after service of this summons upon you,
of
the day of service. If you are being sued as an oficer or agency of the United States Government or the
exclusive

Distict of Columbia Govenment, you have sixty (60) days ater service of this summons to serve your
Answer. A copy of the Answer must be mailed t > the attoney for the party plaintiff who is suing you. The
attorney's name and address appear below. If plaintiff has no attorney, a copy of the Answer must be
mailed to the plaintiff at the address stated on this
Summons.
You arc also required to file the original Answer with the Court in Room JM 170 at 500 Indiana
Avenue, N.W., between 8:30 a.m. and 5:00 p.m., Mondays through Fidays or between 9:00 a.m. and
noon
12:00 on Saturdays. You may ile the oiginal Answer with the Cout either before you serve a copy of the

Answer on the plaintiff or within ive (5) days ater you have served the plaintiff If you fail to ile an
Answer judgment by default may be entered against you for the relief demanded in the
complaint.
Clerk of the Court

oS
hivne of P
bint i

/wy\

Attorney

%^\3r> <

y
3 ~7

"23

o/d

Date

Telephone

PUEOE OBTENERSE COPIAS OE ESTE FORMUlARlO EN ESPANOL EN EL TRIBUNAL SUPERIOR DEL

DISTRJTO DE COLUMBIA, 500 INDIANA AVENUE, N.W SALA JM 170

VOU MAY OBTAIN A COPY OF

AVENUE, N.W, ROOM JM HO

i FORM IN SPANISH AT THE SUPERIOR COURT OF D.C, 500 INDIANA

NOTE: SEE IMPORTANT IMF 3RMATION ON BACK OF THIS FORM

CVw4SvM|

CAForml

Superior Court of the District of Columbia

civV L DIVISHON
500 l&dJana AvIeaue,N.W., Room JM-170
Washington, D.C 20001 Telephone: 879-1133

(\YM0 ABU AT-TA

-10

Plaintif

vs.mMtJ*"n

Civil Action No.

/AC

UMMONS

To the above named

Defendant:
You are hereby summoned and rcqui
personally or through an attorney, within twenty
(of the day of service. If you are being sued as
Distict of Columbia Government, you have si
s
Answer. A copy of the Answer must be mailed t

to serve an Answer to the attached Complaint, either

0) days ater service of this summons upon you,
officer
or agency of the United States Government or the
exclusive

y (60) days ater service of this summons to serve your

> the attorney for the paty plaintiff who is suing you. The
attorney's name and address appear below. If plaintiff has no attorney, a copy of the Answer must be
mailed to the plaintiff at the address stated on
thi

Summons.

You are also required to ile the oiginal Answer with the Court in Room JM 170 at S00 Indiana

Avenue, N.W., between 8:30 a.m. and 5:00 p.m., Mondays through Fidays or between 9:00 a.m. and
noon
12:00 on Saturdays. You may ile the oiginal Answer with the Cout either before you serve a copy of the

Answer on the plaintiff or within ive (5) days ater you have served the plaintiff If you fail to file an
Answer, judgment by default may be entered agai isi you for the relief demanded in the
complaint.
Clerk of the Court

ie,

?eksr\)f<**K

Name of PlwjhifTs Attoney

2 1

Address

aAWv

By

y
2l7

lerk

Date

Telephone

PUEDE OBTENERSE COP1AS DE ESTE FORMUlARJO EN ESPANOL EN EL TRIBUNAL SUPERIOR DEL

DISTRJTODE COLUMBIA, 500 INDIANA AVENUE, N.WMSALAJM 170
YOU MAY OBTAIN A COPY OF THIS FORM IN

AVENUE, N.W., ROOM JM 170

AT THE SUPERIOR COURT OF D.C, 500 INDIANA

NOTE: SEE IMPORTANT IMF ORMATION ON BACK OF THIS FORM.

CvitHMttU) U

kF

CJ

A Form 1

Superior Court of the District of Columbia

civil division
500 Indiana Avenue, N.Wn Room JM-170
Washington, D.C. Z0001 Telephone: 879-1133

aYmm

TTA

ABU

1C
Plaintif

vs.

Civil Action No

CBS Bioi>ASTZ/l/G,Zi/c.
Defendant

SUMMONS

To the above named

Defendant:
You are hereby summoned and requi
to serve an Answer to the attached Complaint, either
personally or through an attorney, within
.0) days ater service of this summons upon you,
of
the day of service. If you are being sued as i exclusive
twenty
oicer or agency of the United States Government or the

Distict of Columbia Government, you have si |ty (60) days ater service of this summons to serve your
Answer. A copy of the Answer must be mailed t t the attoney for the paty plaintiff who is suing you. The
attorney's name and address appear below. I plaintiff has no attoney, a copy of the Answer must be
mailed to the plaintiff at the address stated on
Summons.
thi
You are also required to file the oiginal Answer with the Court in Room JM 170 at 500 Indiana
Avenue, N.W., between 8:30 a.m. and 5:00 p.m., Mondays through Fidays or between 9:00 a.m. and
noon
12:00 on Saturdays. You may ile the oiginal Answer with the Cout either before you serve a copy of the

Answer on the plaintiff or within five (5) days ater you have served the plaintiff If you fail to ile an

Answer, judgment by default may be enteed agai ist you for the relief demanded in the
complaint.
Clerk of the Court

k Pelro'^rew

Nime of Plaintiff Attoney

AA

Addrea

/ yp^^JrrV

ty

lybo/O
Date

Telephone

PUEDE OBTENERSE CO HAS OE ESTE FORMULARIO EN ESPANOL EN EL TRIBUNAL SUPERIOR DEL

DISTRITODE COLUMBIA* 500 INDIANA AVENUE,N.W.,SALAJM170
YOU MAY OBTAIN A COPY OF THIS FORM IN SPANISH AT THE SUPERIOR COURT OF D.C, 500 INDIANA
AVENUE, N.W., ROOM JM 170
NOTE: SEE IMPORTANT INFORMATION ON BACK OF THIS FORM
CV<H tWilij u

( A Form 1

Superior Court ofthe District of Columbia

civ L DIVISION
500 Indiana Avekuc, N.W., Room JM-170
Washington, D.C 20001 Telephone: 879-1133

Ay/W A&V Al

0002966*10

Plaintif

Civil Action No.

vs.

NBCt>l*e,2,

y\c

UMMONS

To the above named

Defendant:

You are hereby summoned and required to serve an Answer to the attached Complaint, either

personally or though ah attoney, within twenty (20) days ater service of this summons upon you, exclusive
of the day of service. If you are being sued as an officer or agency of the United States Government or the
District of Columbia Government, you have sixty (60) days ater service of this summons to serve your
Answer. A copy of the Answer must be mailed t> the attoney for the party plaintiff who is suing you. The

attoney's name and address appear below. If plaintiff has no attoney, a copy of the Answer must be
mailed to the plaintiff at the addess stated on this
Summons.

You are also required to file the original Answer with the Court in Room JM 170 at 500 Indiana
Avenue, N.W,, between 8:30 a.m. and 5:00 p.m., Mondays though Fidays or between 9:00 a.m. and 12:00
noon on Saturdays. You may ile the oiginal Answer with the Court either beforeyou serve a copy of the

Answer on the plaintiff or within ive (5; days ater you have served the plaintiff If you fail to ile an
Answer, judgment by default may be entered against you for the relief demanded in the
complaint.
Clerk of the Court

ee
ee^e
Name of Plainlilri Attorney

Lee, ht 3rd t loer By

"prlexn^&ros. I/A
5/7

yCTerk

Date

Telephone

PUEDE OBTENERSE CO PI AS DE E5TE FORMULARJO EN ESPANOL EN EL TRIBUNAL SUPERIOR DEL

DISTR1TODE COLUMBIA, S00 INDIANA AVENUEN.W..SALAJM170
YOU MAY OBTAIN A COPY OF THIS FORM IN SPANISH AT THE SUPERIOR COURT OF D.C, 500 INDIANA
AVENUE, N.W., ROOM JM 170
NOTE: SEE IMPORTANT INFORMATION ON BACK OF THIS FORM.
tVQ WMi| M

GA Form 1

Superior Court of the District of Columbia

CIVIL DIVISION
500 Indiana Avenue, N.W., Room JM-170
Washington, D.C. 20001 Telephone: 879-1133

Aym*/

ABU AITA
0002966-id

Plaintif

Civil Action No.

vs.

MarMMjAV Roach

SJMMONS
To the above named
Defendant:
You are hereby summoned and requi
personally or through an attoney, within twenty
of the day of service. If you are being sued as i
District of Columbia Government, you have six
Answer. A copy of the Answer must be mailed t

to serve an Answer to the attached Complaint, either

0) days ater service of this summons upon you,
officer or agency of the United States Government or the
exclusive

y (60) days ater service of this summons to serve your

the attorney for the party plaintiff who is suing you. The
attorney's name and address appear below. If plaintiff has no attorney, a copy of the Answer must be
Summons.
mailed to the plaintiff at the address stated on
this
You are also required to file the original Answer with the Cout in Room JM 170 at 500 Indiana
,venuf N.W.t between 8:30 a.m. and 5:00 r.m.,. Mondays through Fidays or between 9:00 a.m. and 12:00
noon on Saturdays. You may file the oiginal Answer with the Cout either beforeyou serve a copy of the

Answer on the plaintiff or within ive (5) days after you have served the plaintiff If you fail to f\\t an
Answer, judgment by default may be entered against you for the elief demanded in the
complaint.
Clerk of the Court

eae IXeeUW
lame o! PlnntifTi Atiwney

2/g M L* g

f~\ *. 3A

Address

/<&

torBy
A

9^20
Date

Telephone

PUEDE OBTENERSE COPIAS DE ESTE FORMuIaRIO EN ESPANOL EN EL TRIBUNAL SUPERIOR DEL

DISTRJTO DE COLUMBIA, 500 INDIANA AVENUE, N.W SALA JM 170

VOU MAY OBTAIN A COPY OF THIS FORM IN SPANISH AT THE SUPERIOR COURT OF D.C, 500 INDIANA
AVENUE, N.W ROOM JM 170
NOTE: SEE IMPORTANT IN! ORMATION ON BACK OF THIS FORM
CV(H-U**U> u

CJ

Cj

CAForal

Superior Court of the District of Columbia

CIVIL DIVISION
500 Indiana Avenue, NAV., Room JM-170
Washington, D.C. 20001 Telephone: 879-1133

AVtW ABu AztA

000296G-10

Plaintif
vs.

Civil Action No.

"PAA/
Defendant

5UMMONS
To the) above named
Defendant:
You are hereby summoned and requi
personally or though an attoney, within twenty
of the day of service. If you are being sued as i

to serve an Answer to the attached Complaint, either

0) days after service of this summons upon you,
officer or agency of the United States Government or the
exclusive

Distict of Columbia Government, you have si y (60) days ater service of this summons to serve your
Answer. A copy of the Answer must be mailed t the attorney for the paty plaintiff who is suing you. The
attorney's name and address appear below. If plaintiff has no attoney, a copy of the Answer must be
Summons.
mailed to the plaintiff at the address stated on
thi
You are also required to file the oiginal Answer with the Court in Room JM 170 at 500 Indiana
Avenue, N.W., between 8:30 a.m. and 5:00
Mondays through Fridays or between 9:00 a.m. and
noon
with the Court either before you serve a copy of the
p.m.. on Saturdays. You may ile the oiginal Answer
12:00

Answer on the plaintiff or within five (5) days ater you have served the plaintiff If you fail to file an
Answer, judgment by default may be entered against you for the relief demanded in the
complaint.
Clerk of the Court

Nme of Plaintiffs Attorney

>

By
Address

o^.

2
37

3^
Date

Telephone

PUEDE OBTENERSE COP IAS DE ESTE FORMUtARIO EN ESPANOL EN EL TRIBUNAL SUPERIOR DEL
DISTRITO DC COLUMBIA, 500 INDIANA AVENUE, N.W^SAXAJM 170
YOU MAY OBTAIN A COPY OF THIS FORM IN SPANISH AT THE SUPERIOR COURT OF D.C. 500 INDIANA
AVENUE, N.W., ROOM JM 170
NOTE: SEE IMPORTANT INFORMATION ON BACK OF THIS FORM.
CVfl twli M

(JA Form 1

Superior Court of the District of Columbia

CIVIL DIVISION
500 Indiana Avenue, N.W., Room JMM70
Washington, D.C. JoOOl Telephone: 879-1133

AMMABO A%iA
0002966-10

Plaintif
Civil Action No.

vs.

tAikSNCS CfML* W&tG<6t>

Defendant

SUMMONS

To the above named

Defendant:
You are hereby summoned and requi
to serve an Answer to the attached Complaint, either
personally or through an attoney, within twenty ( 0) days ater service of this summons upon you,
officer or agency of the United States Government or the
of the day of service. If you are being sued as ai exclusive
District of Columbia Government, you have six y (60) days ater service of this summons to serve your
Answer. A copy of the Answer must be mailed t t the attorney for the party plaintiff who is suing you. The

attorney's name and address appear below. If plaintiff has no attorney, a copy of the Answer must be
mailed to the plaintiff at the address stated on
this

Summons.

You are also required to ile the oiginal Answer with the Court in Room JM 170 at 500 Indiana

Mondays through Fidays or between 9:00 a.m. and 12:00

Avenue, N.W., between 8:30 a.m. and 5:00
noon
p.m., on Saturdays. You may ile the original Answer with the Cout either before you serve a copy of the

Answer on the plaintiff or within ive (5) days iter you have served the plaintiff. If you fail to ile an
Answer, judgment by default may be entered agai ist you for the relief demanded in the
complaint.
Clerk of the Court

TXCAW

Nme of PI tin tiffs Attorney

-7jf AA 1. %3rJ

wr

By

Address

k
Date

Telephone

PUEDE OBTENERSE COPlAS DE ESTE FORMU<-ARIO EN ESPANOL EN EL TRIBUNAL SUPERIOR DEL

DISTRITO DE COLUMBIA, 500 INDIANA AVENUE,N.W.,SALAJM170
YOU MAY OBTAIN A COPY OF THIS FORM IN SPANISH AT THE SUPERIOR COURT OF D.C, 500 INDIANA
AVENUE, N.W., ROOM JM 170
NOTE: SEE IMPORTANT INFORMATION ON BACK OF THIS FORM
cvl mu> m

CA Form 1

Superior Court of the District of Columbia

CIVIL DIVISION
500 Indiana Avenue, N.W., Room JM-170
Washington, D.C. 20001 Telephone: 879-1133

fHHAN A&U AXTA

0002960-10

Plaintif

vs.

Civil Action No.

Hill FU>[5TEZ*I

'Jonah

Defendant

IUMMONS
To the above named
Defendant:

You are hereby summoned and required to serve an Answer to the atached Complaint, either

personally or through ah attorney, within twenty (20) days ater service of this summons upon you,
of
the day of service. If you are being sued as ait officer or agency of the United States Government or the
exclusive

Distict of Columbia Govenment, you have sixty (60) days ater service of this summons to serve your
Answer. A copy of the Answer must be mailed lb the attorney for the parly plaintiff who is suing you. The
attorney's name and address appear below. If plaintiff has no attorney, a copy of the Answer must be

mailed to the plaintiff at the address stated on this

Summons.

You are also required to ile the original Answer with the Cout in Room JM 170 at 500 Indiana
Avenue, N.W., between 8:30 a.m. and 5:00 p.m., Mondays through Fidays or between 9:00 a.m. and
noon
12:00 on Saturdays. You may ile the oiginal Answer with the Court either before you serve a copy of the

Answer on the plaintiff or within five (5) days ater you have served the plaintiff If you fail to ile an
Answer, judgment by default may be entered agai ist you for the relief demanded in the
complaint.
Clerk of the Court

\t

N*me of Plaintiff* At ton

Address

Clerk

t*

J
Date

Telephone

PUEDE OBTENERSE COPIAS DE ESTE FORMUILARJO EN ESPANOL EN EL TRIBUNAL SUPERIOR DEL

DISTRJTO DE COLUMBIA, 500 INDIANA AVENUE, N.WMSALAJM170

YOU MAY OBTAIN A COPY OF THIS FORM IN SPANISH AT THE SUPERIOR COURT OF D.C, 500 INDIANA
AVENUE, N.W., ROOM JM 170
n
NOTE; SEE IMPORTANT INFORMATION ON BACK OF THIS FORM.
CVuHWItiT U

CAForml

Superior Court of the District of Columbia

CIVIL DIVISION
500 Indiana Avenue, N.W., Room JM-170
Washington, D.C ?0001 Telephone: 879-1133

Ay mm Mo crA

002966-10
Civil Action No.

VS.

-&< vi* t^f&JtrrB*fWf

SUMMONS

To the above named

Defendant:
You are hereby summoned and require
personally or through an attorney, within twenty
of
( the day of service. If you are being sued as ar
District of Columbia Government, you have six
Answer. A copy of the Answer must be mailed t

to serve an Answer to the attached Complaint, either

0) days after service of this summons upon you,
officer
or agency of the United States Government or the
exclusive
y (60) days after service of this summons to serve your
the attorney for the party plaintiff who is suing you. The

attorney's name and address appear below. If laintiff has no attorney, a copy of the Answer must be
mailed to the plaintiff at the address stated on
this

Summons.

You are also required to ile the original Answer with the Court in Room JM 170 at 500 Indiana

Avenue, N.W., between 8:30 a.m. and 5:00 p.m., Mondays through Fridays or between 9:00 a.m. and
noon
12:00 on Saturdays. You may ile the oiginal Ar swer with the Cout either before you serve a copy of the

Answer on the plaintiff or within ive (5) days ifler you have served the plaintiff If you fail to file an

Answer, judgment by default may be entered against you for the relief demanded in the
complaint.
Clerk of the Court

N*me of Plaintif's Attoney

Ale'iU Lee Sb&t2if<<

^^ P

Address

51?

3 71?

Clerk

Date

Telephone

PUEDE OBTENERSE COPIAS DE ESTE FORMULARIO EN ESPANOL EN EL TRIBUNAL SUPERIOR DEL

D1STRITO DE COLUMBIA, 500 INDIANA AVENUE, N.W.,SALAJM170

YOU MAY OBTAIN A COPY OF

AVENUE, N.W., ROOM JM 170

i FORM IN SPANISH AT THE SUPERIOR COURT OF D.C, 500 INDIANA

NOTE: SEE IMPORTANT INFORMATION ON BACK OF THIS FORM.

CV)*HH*1, U

Cd

:A Form 1

Superior Court of the District of Columbia

CIVIL DIVISION
500 Indiana Av< Due, N.W^ Room JM-170
Washingon, D.C. 20001 Telephone: 879-1133

AYMA/ AcU AZTA

:)Q0296(MO

Plaintif
Civil Action No.

vs.

Cohe\I
Defendant

SUMMONS

To the above named

Defendant:

You are hereby summoned and required to serve an Answer to the attached Complaint, either
personally or through an attorney, within twenty i20) days after service of this summons upon you,
of the day of service. If you are being sued as ar officer or agency of the United States Government or the
exclusive

District of Columbia Government, you have sixty (60) days ater service of this summons to serve your
Answer. A copy of the Answer must be mailed to the attorney for the party plaintiff who is suing you. The
attorney's name and address appear below. If plaintiff has no attorney, a copy of the Answer must be
mailed to the plaintiff at the address stated on this
Summons.
You are also required to File the original Answer with the Court in Room JM 170 at 500 Indiana
Avenue, N.W., between 8:30 a.m. and 5:00 p.m., Mondays through Fidays or between 9:00 a.m. and
noon
12:00 on Saturdays. You may file the oiginal Answer with the Court either before you serve a copy of the

Answer on the plaintiff or within five (5) days ater you have served the plaintiff; If you fail to ile an

Answer, judgment by default may be entered against you for the relief demanded in the
complaint.
Clerk of the Court
*\

Natme of PltinfifTs Attorney

SL,r

g NosbL L
Address

By

3rJ f^ffOf

M*

ty
Clerk

30/2DI0
Telephone

44

Date

PUEDE OBTENERSE COPIAS DE ESTE FORMULARIO EN ESPANOL EN EL TRIBUNAL SUPERIOR DEL

DISTRJTODE COLUMBIA, 500 INDIANA AVENUE, N.W SALA JM 170
YOU MAY OBTAIN A COPY OF THIS FORM IN SPANISH AT THE SUPERIOR COURT OF D.C, 500 INDIANA
AVENUE, N.W ROOM JM 170
NOTE: SEE IMPORTANT INFORMATION ON BACK OF THIS FORM
CV<tMSVMy U

co

CO

Superior (Court of it* liHtricl of (Columbia

civil division - CIVIL ACTIONS BRANCH
INFORM IATION SHEET

A1HAH Aku AIT,

0002860-10
Case Number:

<J/2o/2e>lo

VS.

Date:

cto.)

GachA MoAt Bazda/

Name:

^}
-3h(please
<sA rprint) /)eies

**~T*>
Pre*^^
"~~

Finn Name; /

cph

Uniied Bar No.:

No.: ^

TYPE OF CASE:

? Non-Jury

Relationship to Lawsuit

ia^i/\
T

<*

__

Sf Attorney for Plaintiff

? Self (Pro Se)

^ Lo 1/r> s

Other:

? 12 Person Jury

%6Person Jury

Demand: $ WO,M0,nlD:

Other:

PENDING CASE(S) RELATED TO THE ACTION BEING FILED

Case No.

Judge

Calendar #

Case No.

Judge

Calendar #

NATURE OF SUIT:

(Check One Box Only)

A. CONTRACTS
D 01 Breach of Contract
D 02 Breach of Warranty
D 06 Negotiable Instrument
D 15 Other:

COLLECTION CASES

D 07 Personal P operty
? 09 Real Property-Real Estate
D 12 Specific Performance

D 14 Under $25,000 Pltf, Grants Consent

D 16 Under $25,000 Consent Denied

D 17 OVER $25,000

B. PROPERTY TORTS

? 03 Destruction^ of Private Property D 05 Trespass

? 01 Automobile
D 04 Propety DJamage
? 02 Conversion
? 06 Other:
? 07 Shoplifting, DX. Code 3-441
C. PERSONAL TORTS
D 01 Abuse of Process

D 09 Harassment
? 02 Alienation of Affecion O 10 Invasion off Privacy
D 03 Assault and Battery t JS 11 Libel and Slander
D 04 Automobile
D 05 Deceit (Misrepresentation)

? 06 False Accusation
D 07 False Arrest

? 08 Fraud

'? 12

Malicious Interference

? 13 Malicious Prosecution
D 14 Malpractice Legal
? 15 Malpractice] Medical
D 16 Negligence

? 17 Personal Injury
D 18 Wrongful Death
? 19 Wrongful Eviction
? 20 Other:
? 21 Asbestos
? 22 Toxic/Mass Torts

SEE REVERSE SIDE At ID CHECK HERE ? IF USED

Fen CV(f)49VJo.

5-WVlwd-3J4

9w

+&

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CIVIL DIVISION

&

AYMAN ABU AITA

C.A. No.

Vs.

SACHA NOAM BARON COHEN

2010 CA 002966
B

INITIAL ORDER AND ADDENDUM

Pursuant to D.C. Code 11-906 and Distict of Columbia Supeior Court Rule of Civil
("SCRProcedure
Civ") 40-1, it is hereby ORDERED as fo
lows:
(1) Effective this date, this case has assigned to the individual calendar designated below. All future
filings
in this
case shall bear the calendar number and the judge's name beneath the case number in the caption.
On
filing any motion or paper related thereto, one c<Jpy (for the judge) must be delivered to the Clerk along
with the
oiginal.
(2) Within 60 days of the filing of the complaint, plaintiff must ile proof of serving on each
defendant:
copies
of the Summons, the Complaint, and this Initial Order. As to any defendant for whom such proof of
service has not been iled, the Complaint will be dismissed without prejudice for want of prosecution unless
the
time for serving the defendant has been extended as provided in SCR Civ
4(m).
(3) Within 20 days of service as described above, except as otherwise noted in SCR Civ 12, each
mustdefendant
respond to the Complaint by iling an Answer or other responsive pleading. As to the defendant who
has
failed to respond, a default and judgment will be entered unless the time to respond has been extended as
provided in SCR Civ
55(a).
(4) At the time and place noted below, i til counsel and unrepresented parties shall appear before the
assigned judge at an Initial Scheduling and Settlement Conference to discuss the possibilities of settlement
and
to establish a schedule for the completion of all proceedings, including, normally, either mediation, case
evaluation, or arbitration. Counsel shall discuss ' vith their clients prior to the conference whether the clients
are
This order is the only notice that parties and counsel will
agreeable to binding or non-binding
arbitration.
receive concerning this
Conference.
(5) Upon advice that the date noted beloiwj is inconvenient for any paty or counsel, the Quality Review
Branch (202) 879-1750 may continue the Conference once, with the consent of all parties, to either of the
two
succeeding Fidays. Request must be made not less than six business days before the scheduling
conference
date.
No
other continuance
of the conference will be granted except upon motion for good cause
shown.
(6) Parties are responsible for obtaining andl complying with all requirements of the General Order for
Civil
cases,
each Judge's Supplement to the General C rder and the General Mediation Order. Copies of these
orders
are available in the Courtroom and on the Court's website
http://www.dccourts.eov/.
Chief Judge Lee F.
Sattefield
Case Assigned to: Judge JUDITH
BARTNOFF
Date: April 30,2010
Initial Conference: 9:00 am, Friday, July
30,201Q Courtroom 100
Location:
500 Indiana Avenue
C a to.
N.W.
WASHINGTON,
DC 20001
doc

9
ADDENDUM TO INITIAL ORDER AFFECTING
ALL MEDICAlt MALPRACTICE CASES
In accordance with the Medical Malpractice Proceedings Act of 2006, D.C. Code
et seq.16-2801,
(2007 Winter Supp.), "[ajter an action is iled in the court against a healthcare provider
alleging medical malpractice, die court shall require the parties to enter into mediation, without
discovery or, if all parties agree[,] with qnly limited discovery that will not interfere with the
completion of mediaion within 30 days of the Initial Scheduling and Settlement Conference
("ISSC"), pior to any further litigation in an effort to reach a settlement agreement. The early
mediation schedule shall be included in the Scheduling Order following the ISSC. Unless all
parties agree, the stay of discovery shall be more than 30 days ater the ISSC." D.C. Code
16not
2821.
To ensure compliance with this legislation, on or before the date of the ISSC, the Court
will
notify all
attorneys wd pro se parties of the date and time of the early mediation session and the
name of the assigned mediator. Information about the early mediation date also is available
overinternet at https://www:dccouts.gov/pa/. To facilitate this process, all counsel and pro se
the
parties in every medical malpractice case [are required to confer, jointly complete and sign an
EARLY MEDIATION FORM, which must be iled no later than ten (10) calendar days pior to the

ISSC. Two separate Early Mediation Fcrms are available. Both forms may be obtained at
www.dccourts.gov/medmalmediation. One form is to be used for early mediation with a mediator
from the multi-door medical malpractice mediator roster; the second form is to be used for early

mediation with a private mediator. Both forms also are available in the Multi-Door Dispute
Resolution Ofice, Suite 105, 515 5th Street, N.W. (enter at Police Memoial Plaza entrance).
Plaintiffs counsel is responsible for eFiling the form and is required to e-mail a courtesy copy to
[email protected]. Pro se Plaintiffs wjho elect not to eFile may ile by hand in the
Multi-Door
Dispute Resolution
Office.
A roster of medical malpractice med ators available through the Court's Multi-Door
Dispute
Resolution
Division, with biographical information about each mediator, can be found at
www.dccourts.gov/medmalmediation/media orproiles. All individuals on the roster are judges or
lawyers with at least 10 years of significant < xpeience in medical malpractice litigation. D.C.
Code
16-2823(a). If the parties cannot agree oiji a mediator, the Court will appoint one. D.C. Code
16-2823(b).

The following persons are required by statute to attend personally the Early Mediation
Conference: (1) all parties; (2) for parties that arc not individuals, a representative with
settlement
authoity; (3) in cases involving an insurance company, a representative of the company with
settlement authoity; and (4) attorneys representing each party with primary responsibility for the
case. D.C. Code
16-2824.
No later than ten (10) days ater the early mediation session has terminated, Plaintiff
mediator, including a pivate mediator, regarding: (1)
eFile with the Court a report prepared by must
th
ached; or, (3) if a settlement was not reached, any
attendance;
(2) whether a settlement
was
agreements to narrow the scope of the di ute, limit discovery, facilitate future settlement, hold
another mediation session, or otherwise ce the cost and time of trial preparation. D.C. Code
ed
16-2826. Any Plaintiff who is pro se may elect to ile the report by hand with the Civil Clerk's

Oice.

The forms to be used for early mediation reports are available at

www.dccouts.gov/medmalmediation.

Chief Judge Lee F.

Satterield
Caio.doc

a*

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CIVIL DIVISION

0+
cQ

AYMAN ABU AITA

C.A. No.

Vs.

2010 CA 002966 B

SACHA NOAM BARON COHEN

INITIAL

ER AND ADDENDUM

Pursuant to D.C. Code 11-906 and District of Columbia Supeior Court Rule of Civil Procedure
("SCR Civ") 40-1, it is hereby ORDERED as fo Hows:

(1) Effective this date, this case has assigned to the individual calendar designated below. All future ilings
in this case shall bear the calendar number and the judge's name beneath the case number in the caption. On
iling any motion or paper related thereto, one cqpy (for the judge) must be delivered to the Clerk along with the

oiginal.
(2) Within 60 days of the iling of the comp aint, plaintiff must ile proof of serving on each defendant:
copies of the Summons, the Complaint, and thi s Initial Order. As to any defendant for whom such proof of
service has not been iled, the Complaint will be dismissed without prejudice for want of prosecution unless the
time for serving the defendant has been extended as provided in SCR Civ 4(m).
(3) Within 20 days of service as described sbove, except as otherwise noted in SCR Civ 12, each defendant
must respond to the Complaint by iling an Answer or other responsive pleading. As to the defendant who has
failed to respond, a default and judgment will be entered unless the time to respond has been extended as
provided in SCR Civ 55(a).

(4) At the time and place noted below, all counsel and unrepresented parties shall appear before the
assigned judge at an Initial Scheduling and Settlement Conference to discuss the possibilities of settlement and

to establish a schedule for the completion of all proceedings, including, normally, either mediation, case
evaluation, or arbitration. Counsel shall discuss' vith their clients prior to the conference whether the clients are
agreeable to binding or non-binding arbitration. This order is the only notice that parties and counsel will
receive concerning this Conference.

(5) Upon advice that the date noted below is inconvenient for any party or counsel, the Quality Review
Branch (202) 879-1750 may continue the Confeence once, with the consent of all parties, to either of the two
succeeding Fridays. Request must be made not less than six business days before the scheduling conference date.
No other continuance of the conference will be granted except upon motion for good cause shown.

(6) Parties are responsible for obtaining andl complying with all equirements of the General Order for Civil
cases, each Judge's Supplement to the General Order and the General Mediation Order. Copies of these orders
are available in the Courtroom and on the Court'! website http://www.dccourts.gov/.

Chief Judge Lee F. Satterield

Case Assigned to: Judge JUDITH BARTNOFF

Date: Apil 30,2010

Initial Conference: 9:00 am, Friday, July 30,201(jl
Location: Courtroom 100
500 Indiana Avenue N.W.

WASHINGTON, DC 20001

Cato.doc

ADDENDUM TO

ALL MEDIC

ITIAL ORDER AFFECTING

MALPRACTICE CASES

In accordance with the Medical Malpractice Proceedings Act of 2006, D.C. Code
16-2801,
et
(2007 Winter Supp.), "[ajter an action is iled in the court against a healthcare provider
seq.
alleging medical malpractice, the court shall require the parties to enter into mediation, without

discovery or, if all parties agree[,] with only limited discovery that will not interfere with the
completion of mediation within 30 days of the Initial Scheduling and Settlement Conference
("ISSC"), prior to any further litigation in an effot to reach a settlement agreement. The early
mediation schedule shall be included in the Scheduling Order following the ISSC. Unless all
paties agree, the stay of discovery shall not be more than 30 days ater the ISSC." D.C. Code
162821.
To ensure compliance with this legislation, on or before the date of the ISSC, the Court
willatorneys and pro se parties of th i date and time of the early mediation session and the
notify all
name of the assigned mediator. Informatio i about the early mediation date also is available over
the internet at https://www:dccourts.gov/p/. To facilitate this process, all counsel and pro se
parties in every medical malpractice case are required to confer, jointly complete and sign an
EARLY MEDIATION FORM, which must >e iled no later than ten (10) calendar days prior to the

ISSC. Two separate Early Mediation Forms are available. Both forms may be obtained at
www.dccourts.gov/medmalmediation. One form is to be used for early mediation with a mediator
rom the multi-door medical malpractice mediator roster; the second form is to be used for early

mediation with a pivate mediator. Both forms also are available in the Multi-Door Dispute
Resolution Oice, Suite 105, 515 5th Str et, N.W. (enter at Police Memoial Plaza entrance).
Plaintiffs counsel is responsible for eFilingj the form and is required to e-mail a courtesy copy to
[email protected]. Pro se Plaintiffs who elect not to eFile may file by hand in the
Multi-Door
Dispute Resolution
Ofice.
A roster of medical malpractice mediators available through the Court's Multi-Door
Dispute
Resolution
Division, with biographical information about each mediator, can be found at
www.dccourts.gov/medmalmediation/mediajorproiles. All individuals on the roster are judges or
lawyers with at least 10 years of signiicant experience in medical malpractice litigation. D.C.
Code
l6-2823(a). If the parties cannot agree oiji a mediator, the Court will appoint one. D.C. Code
16-2823(b).

by statute to attend personally the Early Mediation

t are not individuals, a representative with
ce company, a representative of the company with
authoity; (3) in cases involving an insur settlement
settlement authoity; and (4) attorneys repr senting each party with pimary responsibility for the
case. D.C. Code
16-2824.
No later than ten (10) days ater the early mediation session has terminated, Plaintiff
mediator, including a pivate mediator, regarding: (1)
eFile with the Cout a report prepared by th must
atendance; (2) whether a settlement was eached; or, (3) if a settlement was not reached, any
ute, limit discovery, facilitate future settlement, hold
agreements to narrow the scope of the
dis
another
mediation session, or otherwise ce the cost and time of trial preparation. D.C. Code
red
16-2826. Any Plaintif who is pro se may elect to ile the eport by hand with the Civil Clerk's
The following persons are require
Conference: (I) all parties; (2) for parties

Oice.

The forms to be used for early mediation reports are available at

www.dccourts.gov/medmalmediation.

Chief Judge Lee F. Saterield

Caio.doc