MGM Resorts International et al v. Corbin et al

Filing 1

COMPLAINT for Declaratory Relief against Dawni L. Corbin, Jamie Huddleston, Avonna Murfitt, Shannon Pendergrass, Magen Schiermbock, Kelli Turnbow ( Filing fee $ 400 receipt number 097--2550882.), filed by Mandalay Resort Group, MGM Resorts Festival Grounds, LLC, MGM Resorts Venue Management, LLC, MGM Resorts International, Mandalay Bay, LLC.(Felder, Brian)

WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
555 South Flower Street, Suite 2900
Los Angeles, CA 90071-2407

E. STRATTON HORRES, JR. (Pro Hac Vice Forthcoming)
[e-mail]
B. OTIS FELDER, ABA #511081
[e-mail]
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
555 South Flower Street, Suite 2900
Los Angeles, California 90071
Tel: [phone] / Fax: [phone]
BRAD D. BRIAN (Pro Hac Vice Forthcoming)
[e-mail]
MICHAEL R. DOYEN (Pro Hac Vice Forthcoming)
[e-mail]
BETHANY W. KRISTOVICH (Pro Hac Vice Forthcoming)
[e-mail]
MUNGER, TOLLES & OLSON LLP
350 South Grand Avenue, Fiftieth Floor
Los Angeles, California 90071-3426
Tel: [phone] / Fax: [phone]
Attorneys for Plaintiffs MGM RESORTS INTERNATIONAL,
MANDALAY RESORT GROUP, MANDALAY BAY, LLC,
MGM RESORTS FESTIVAL GROUNDS, LLC, and
MGM RESORTS VENUE MANAGEMENT, LLC
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ALASKA
MGM RESORTS INTERNATIONAL,
MANDALAY RESORT GROUP,
MANDALAY BAY, LLC, MGM RESORTS
FESTIVAL GROUNDS, LLC, and MGM
RESORTS VENUE MANAGEMENT, LLC,

Case No. 3:18-cv-00168-TMB
COMPLAINT FOR
DECLARATORY RELIEF
(28 U.S.C. §§ 2201 and 2202)

Plaintiffs,
vs.
DAWNI L. CORBIN, JAMIE HUDDLESTON,
AVONNA MURFITT, SHANNON
PENDERGRASS, MAGEN SCHIERMBOCK,
and KELLI TURNBOW,
Defendants.

COMPLAINT FOR DECLARATORY RELIEF
MGM RESORTS INT’L et al. v. CORBIN et al.
Case No. 3:18-cv-00168-TMB
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JURISDICTION AND VENUE
1.

This Court has subject-matter jurisdiction pursuant to 28 U.S.C. § 1331 and

6 U.S.C. § 442(a). As set forth in detail below, the Support Anti-Terrorism by Fostering
Effective Technologies Act of 2002, 6 U.S.C. §§ 441-444 (also known by the acronym, the
“SAFETY Act”), expressly provides for original and exclusive federal jurisdiction over
actions arising from or relating to acts of mass violence where technologies or services
certified by the Secretary of Homeland Security were deployed. At the time of Paddock’s

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mass attack at the Route 91 concert, security services were provided by Contemporary
Services Corporation as the Security Vendor for the Route 91 Harvest Festival. CSC’s
security services were certified by the Secretary of Homeland Security under the SAFETY
Act.
2.

In addition, the Court has jurisdiction pursuant to 28 U.S.C. § 1332 in that

Plaintiffs (by virtue of their incorporation and principal places of business) are citizens of the
States of Delaware and Nevada; Defendants are citizens of the State of Alaska; and as to
some or all Defendants, the matter in controversy exceeds, exclusive of interest and costs, the
sum specified by 28 U.S.C. § 1332. As to Defendants whose claims individually do not meet
the amount-in-controversy threshold of 28 U.S.C. § 1332(a), this Court has supplemental
jurisdiction over such claims under 28 U.S.C. § 1367 because those claims are so related to
claims of parties whose claims do meet the amount-in-controversy threshold of 28 U.S.C. §
1332(a) that they form part of the same case of controversy under Article III of the United
States Constitution, because all claims arise out of the same occurrence, viz., the mass attack
perpetrated by Stephen Paddock at the Route 91 Harvest Festival in Las Vegas on October 1,
2017.
3.

This Court has personal jurisdiction over Defendants because they are citizens

of the State of Alaska and are therefore subject to the general personal jurisdiction of this
Court.
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4.

Venue is proper in this Judicial District pursuant to 28 U.S.C. § 1391(b)(1)

because one or more of the Defendants are known to reside, or upon information and belief,
do reside, within this Judicial District.
INTRODUCTION
5.

On October 1, 2017, Stephen Paddock carried out a mass attack at the Route

91 Harvest Festival in Las Vegas, Nevada.

WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
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6.

Paddock intended to inflict mass injury, death and destruction. He killed 58

persons and injured some 500 others. Paddock’s attack resulted in the highest number of
deaths of any mass shooting in the Nation’s history.
7.

Security for the concert was provided by Contemporary Services Corporation,

whose security services have been certified by the Secretary of Homeland Security for
protecting against and responding to acts of mass injury and destruction.
8.

Recognizing the national interest in such events, and in the development and

deployment of services certified by the Secretary of Homeland Security to prevent and
respond to such events, Congress has provided original and exclusive federal jurisdiction for
any claims of injuries arising out of or relating to mass violence where services certified by
the Department were deployed.
9.

Plaintiff MGM Resorts Festival Grounds, LLC owns and operates the Las

Vegas Village, at 3901 South Las Vegas Boulevard, Las Vegas, Nevada 89119, where the
Route 91 Harvest Festival was held. Plaintiff Mandalay Bay, LLC owns and operates the
Mandalay Bay resort, which is adjacent to Las Vegas Village. Plaintiff MGM Resorts
International is the parent corporation, with an indirect 100% interest in Mandalay Bay, LLC,
and MGM Resorts Festival Grounds. Plaintiff MGM Resorts Venue Management, LLC is a
Nevada limited liability company.

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10.

Paddock carried out his mass attack on the concert from a room on the 32nd

floor of the Mandalay Bay resort.
11.

Following Paddock’s attack, over 2,500 individuals (“Claimants”) have

brought lawsuits, or threatened to bring lawsuits, against Plaintiffs MGM Resorts Festival
Grounds, LLC, MGM Resorts International, Mandalay Bay, LLC, Mandalay Resort Group,
and MGM Resorts Venue Management, LLC (collectively, “the MGM Parties”), alleging
that the MGM Parties (among others) are liable for deaths, injuries, and emotional distress

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resulting from Paddock’s attack. Claimants subsequently voluntarily dismissed these cases
before they could be resolved, apparently with the intent of refiling.
12.

Named as defendants in this case are Claimants who have brought lawsuits

(which they subsequently voluntarily dismissed) against the MGM Parties, alleging claims
arising from Paddock’s attack, and persons who, through counsel, have threatened to bring
such claims against the MGM Parties.
13.

Congress has enacted legislation to support the development of new

technologies and services to prevent and respond to mass violence. That legislation, the
Support Anti-Terrorism by Fostering Effective Technologies Act of 2002, 6 U.S.C. §§ 441444 (also known by the acronym, the “SAFETY Act”), provides a calibrated balance of
remedies and limitations on liabilities arising from mass attacks committed on U.S. soil
where services certified by the Department of Homeland Security were deployed.
14.

In the case of Paddock’s mass attack, certified technologies or services were

deployed by a professional security company, Contemporary Services Corporation (“CSC”),
which was employed as the Security Vendor for the Route 91 concert. As alleged in more
detail below, Paddock’s mass attack meets the requirements of the SAFETY Act as set forth
in the statute and the Regulations promulgated by the Department of Homeland Security.

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15.

Defendants’ actual and threatened lawsuits implicate the services provided by

CSC because they implicate security at the concert, for example security training, emergency
response, evacuation, and adequacy of egress.
16.

As a result, the SAFETY Act applies to and governs all actions and any

claims arising out of or relating to Paddock’s mass attack. There are five key aspects of the
Act and implementing regulations promulgated by the Department of Homeland Security as
authorized and contemplated by the SAFETY Act. 6 C.F.R. § 25.1 et seq.

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17.

First, the SAFETY Act creates a “Federal cause of action for claims arising

out of [or] relating to” an act of mass violence where certified services were deployed and
where such claims may result in losses to the Seller of the services. 6 U.S.C. § 442(a)(1).
18.

Second, the SAFETY Act expressly provides the federal courts with “original

and exclusive jurisdiction over all actions for any claim for loss” arising out of or related to
such an attack. 6 U.S.C. § 442(a)(2).
19.

Third, as confirmed by the Secretary’s implementing regulations promulgated

after enactment of the SAFETY Act, the federal cause of action created by the statute is the
exclusive claim available in such circumstances. 6 U.S.C. § 442(a)(1). The regulations state:
“There shall exist only one cause of action for loss of property, personal injury, or death for
performance or non-performance of the Seller’s Qualified Anti–Terrorism Technology in
relation to an Act of Terrorism.” 6 C.F.R. § 25.7(d).
20.

Fourth, the regulations further provide that “Such cause of action may be

brought only against the Seller of the Qualified Anti–Terrorism Technology and may not be
brought against the buyers, the buyers’ contractors, or downstream users of the Technology,
the Seller's suppliers or contractors, or any other person or entity.” 6 C.F.R. § 25.7(d).
21.

Fifth, to ensure compensation for victims in appropriate cases, the SAFETY

Act requires that the Seller “obtain liability insurance of such types and in such amounts as
shall be required in accordance with this section and certified by the Secretary to satisfy
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otherwise compensable third-party claims arising out of, relating to, or resulting from an act
of terrorism.” 6 U.S.C. § 443(a)(1).
22.

Congress enacted the SAFETY Act in recognition of the strong national

interest in encouraging the development and use of technologies and services that can help
prevent and respond to mass violence. The Act does so in part by assurance of limited
liability in the unfortunate event that an incident of mass violence occurs and injuries occur
despite the deployment of such technology. The Act also does so by creating original and

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exclusive jurisdiction for the resolution of all controversies in federal court. 6 U.S.C. §
442(a)(2).
23.

The SAFETY Act expressly provides the federal courts with original and

exclusive jurisdiction over “all actions for and any claims for loss [or] injury” arising out of
or relating to a mass attack where certified services were provided and where such claims
may result in losses to the seller of those services. The Act and the associated regulations
make clear that any such claim against the MGM Parties must be dismissed.
24.

By this action, the MGM Parties seek a declaratory judgment and further

relief pursuant to the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202, that the MGM
parties cannot be held liable to Defendants for deaths, injuries, or other damages arising from
Paddock’s attack.
PARTIES
B.

PLAINTIFFS

25.

Plaintiff MGM RESORTS INTERNATIONAL is a Delaware corporation

with its principal place of business in Las Vegas, Nevada. MGM RESORTS
INTERNATIONAL is a citizen of Delaware and Nevada for purposes of diversity
jurisdiction.

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26.

Plaintiff MANDALAY RESORT GROUP is a Nevada corporation with its

principal place of business in Las Vegas, Nevada. MANDALAY RESORT GROUP is a
citizen of Nevada for purposes of diversity jurisdiction.
27.

Plaintiff, MANDALAY BAY, LLC is a Nevada limited liability company

with a single member, Mandalay Resort Group. MANDALAY BAY, LLC is a citizen of
Nevada for purposes of diversity jurisdiction.
28.

Plaintiff MGM RESORTS FESTIVAL GROUNDS, LLC is a Nevada limited

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liability company with a single member, Mandalay Resort Group. MGM RESORTS
FESTIVAL GROUNDS, LLC is a citizen of Nevada for purposes of diversity jurisdiction.
29.

Plaintiff MGM RESORTS VENUE MANAGEMENT, LLC is a Nevada

limited liability company with a single member, MGM Resorts International. MGM
RESORTS VENUE MANAGEMENT, LLC is a citizen of Nevada and Delaware for
purposes of diversity jurisdiction.
C.

DEFENDANTS

30.

Plaintiffs are informed and believe and thereon allege that Defendant Dawni

L. Corbin is a citizen of the State of Alaska. Defendant has, through counsel, asserted or
threatened to assert claims against Plaintiffs based upon the October 1, 2017, shooting
incident in Las Vegas, Nevada.
31.

Plaintiffs are informed and believe and thereon allege that Defendant Jamie

Huddleston is a citizen of the State of Alaska. Defendant has, through counsel, asserted or
threatened to assert claims against Plaintiffs based upon the October 1, 2017, shooting
incident in Las Vegas, Nevada.
32.

Plaintiffs are informed and believe and thereon allege that Defendant Avonna

Murfitt is a citizen of the State of Alaska. Defendant has, through counsel, asserted or
threatened to assert claims against Plaintiffs based upon the October 1, 2017, shooting
incident in Las Vegas, Nevada.
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33.

Plaintiffs are informed and believe and thereon allege that Defendant Shannon

Pendergrass is a citizen of the State of Alaska, County of Matanuska-Susitna Borough.
Defendant has, through counsel, asserted or threatened to assert claims against Plaintiffs
based upon the October 1, 2017, shooting incident in Las Vegas, Nevada.
34.

Plaintiffs are informed and believe and thereon allege that Defendant Magen

Schiermbock is a citizen of the State of Alaska. Defendant has, through counsel, asserted or
threatened to assert claims against Plaintiffs based upon the October 1, 2017, shooting

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incident in Las Vegas, Nevada.
35.

Plaintiffs are informed and believe, and thereon allege, that defendant Kelli

Turnbow is a citizen of the State of Alaska. Defendant has previously filed a lawsuit (which
was subsequently dismissed) against one or more of the Plaintiffs, asserting claims arising
from the October 1, 2017, shooting incident in Las Vegas, Nevada. Based on the allegations
in that lawsuit, filed November 20, 2017, in the Los Angeles Superior Court (“LASC”), case
number BC684047, Plaintiffs are informed and believe that Defendant is a citizen of the
State of Alaska.
FIRST CAUSE OF ACTION FOR DECLARATORY RELIEF
(By Plaintiffs against all Defendants)
36.

Plaintiffs reallege and incorporate by reference, as though fully set forth, the

allegations of paragraphs 1-35, above.
37.

Following Paddock’s mass attack on the concert, over 2,500 individuals have

either sued the MGM Parties, or threatened to sue the MGM Parties, for claims alleged to
arise from or relate to the attack. Several hundred individuals filed suit, and before the issues
could be joined or resolved, they dismissed their claims, apparently with the intent of
refiling.
38.

Each Defendant either (a) has previously filed suit (and then dismissed it)

against one or more of the MGM Parties relating to the Paddock attack, or (b) through
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counsel has stated an intention to sue the MGM Parties relating to the attack. There is no
pending litigation between Plaintiffs and Defendants relating to the attack.
39.

The claims alleged in the now-dismissed lawsuits include claims of alleged

negligence by the MGM Parties and others, including CSC, in protecting and safeguarding
persons including those Defendants who attended the Route 91 Festival.
40.

Defendants’ actual and threatened lawsuits implicate the services provided by

CSC because they implicate security at the concert, including training, emergency response,

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evacuation and adequacy of egress.
41.

These claims are subject to the SAFETY Act, because (a) they arise from and

relate to an act of mass violence meeting the statutory requirements; (b) CSC provided
security at the concert, deploying services certified by the Department of Homeland Security
under the SAFETY Act to protect against or respond to such an attack; and (c) the claims
may therefore result in loss to CSC as the “Seller” of such certified services.
42.

The claims threatened against the MGM Parties by certain Defendants,

through counsel, also inevitably fall under the SAFETY Act for the very same reasons: (a)
they arise from and relate to an act of mass violence meeting the statutory requirements; (b)
CSC provided security at the concert, deploying services certified by the Department of
Homeland Security under the SAFETY Act to protect against or respond to such an attack;
and (c) the claims may therefore result in loss to CSC as the “Seller” of such certified
services. If Defendants were injured by Paddock’s assault, as they allege, they were
inevitably injured both because Paddock fired from his window and because they remained
in the line of fire at the concert. Such claims inevitably implicate security at the concert—and
may result in loss to CSC.
43.

The SAFETY Act applies to claims “arising out of, relating to, or resulting

from an act of terrorism.”

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44.

The SAFETY Act defines an act of terrorism: An act meets the requirements

if the act is (i) “unlawful” (ii) “causes harm to a person … in the United States,” and (iii)
“uses or attempts to use … weapons … designed or intended to cause mass … injury.” 6
U.S.C. § 444(2)(B). There is no requirement in the statute or regulations of an ideological
motive or objective for the attack for it to meet the requirements of the SAFETY Act.
45.

Paddock’s mass attack satisfies the requirements of the SAFETY Act and the

regulations: (i) it was “unlawful,” (ii) it resulted in death or injury to hundreds of persons in

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the United States, and (iii) it involved weapons and other instrumentalities that were designed
and intended to cause, and which in fact caused, mass injury and death. Those weapons and
instrumentalities included rifles modified with bump stocks to spray fully automatic gun fire;
high-capacity magazines capable of holding between 60 and 100 rounds; and illegal
incendiary rounds intended to blow up the fuel tanks adjacent to the concert. Paddock used
these weapons and instrumentalities to fire hundreds of rounds at the crowd, and he fired
incendiary rounds which struck the fuel tanks but, fortunately, missed the fuel.
46.

The post-attack investigation revealed that Paddock brought in his van, which

he parked in the hotel garage, 90 pounds of explosives, consisting of 20 two-pound
containers of exploding targets, 10 one-pound containers of exploding targets and 2 twentypound bags of explosive precursors.
47.

No MGM Party attempted to commit, knowingly participated in, aided,

abetted, committed, or participated in any conspiracy to commit any act of terrorism of
criminal act related to mass attack perpetrated by Stephen Paddock at the Route 91 Harvest
Festival in Las Vegas, Nevada, on October 1, 2017.
48.

The Secretary of Homeland Security may make a determination that conduct

in question meets the statutory requirement, but neither the Act nor the regulations requires a
formal certification. The Statute provides that the Secretary shall have exclusive authority to

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certify services, but the authority to determine whether an act of mass violence meets the
statutory requirements is not exclusive to the Secretary.
49.

Public statements by the Secretary of Homeland Security concerning the

attack make clear that the attack meets the requirements of the SAFETY Act; indeed, based
on the plain language of the statute, the regulations, and the facts, no other determination
could be possible.
50.

In congressional testimony on November 30, 2017, the Acting Secretary of

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Homeland Security noted the emphasis of “terrorists and other violent criminals … on
attacking soft targets,” including “recent tragedies in Nevada.” The Acting Secretary went
on to note that the “SAFETY Act Program” “provide[s] critical incentives for the
development and deployment of anti-terrorism technologies by providing liability protections
for ‘qualified anti-terrorism technologies,’” which applies to a number of large sports and
entertainment venues nationwide.
51.

In a May 2018 release, Department of Homeland Security noted that “mass

shootings” in various places, including at a “concert,” aim “to kill and maim unsuspecting
individuals” and thereby fall within the Department’s “primary mission” “to prevent terrorist
attacks within the U.S, reduce the vulnerability of the U.S. to terrorism, and minimize the
damage and assist in the recovery from terrorist attacks that do occur, including those in STCPs [soft-targets-crowded places].” Department of Homeland Security, Soft Targets and
Crowded Places Security Plan Overview, May 2018, at page 2. The report goes on to note
that the protections of the SAFETY Act have been “approved for open venues such as sports
arenas and stadia” – such as the venue for the Route 91 Festival. Id. at p. 17.
52.

The Department continues its critical work to prevent and respond to mass

violence. In Congressional testimony on May 15, 2018, the Secretary testified that DHS is
“seeking to ramp up ‘soft target’ security efforts,” noting that DHS programs “address threats
to soft targets – including schools, entertainment venues, major events, and public spaces”
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(emphasis added). Further, on June 4, 2018, DHS announced that it had “developed a ST-CP
Security Enhancement and Coordination Plan,” which has not been made public. The plan
addresses “the increased emphasis by terrorists and other extremist actors to leverage less
sophisticated methods to inflict harm in public areas … such as parks, … special event
venues, and similar facilities.” See https://www.dhs.gov/publication/securing-soft-targetsand-crowded-spaces (emphasis added).
53.

The SAFETY Act creates a single, exclusive federal cause of action for claims

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for injuries arising out of or relating to acts of mass violence where services certified by the
Department of Homeland Security were deployed in defense against, response to, or recovery
from such act and such claims result or may result in loss to the Seller.
54.

Pursuant to the SAFETY Act, the Department of Homeland Security has

certified the services provided by CSC. The DHS Certification recognizes CSC’s security
services as appropriate for preventing and responding to acts of mass violence. 6 U.S.C. §
441; see also 48 C.F.R. § 50.201.
55.

CSC’s security services Certified by DHS include “Physical Security”;

“Access Control”; and “Crowd Management.”
56.

CSC’s Certified Crowd Management Services include:



“Awareness of venue-specific emergency response protocols and evacuation

procedures to include emergency alert and mass-notification systems and sheltering
procedures”;


“Pre-event venue / event safety inspections”;



“Facilitation of crowd movement during ingress, circulation, sheltering in

place, emergency evacuations, and egress”;


“Pre-event coordination and multi-agency collaboration with public safety

agencies”;


“Selection, vetting, and training of employees.”

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57.

As alleged above, CSC was employed as the Security Vendor for the Route 91

concert. CSC’s responsibilities at the Route 91 Harvest Festival included providing the
following DHS Certified Services:
“perimeter security, event access, festival grounds event security”;



“Staff[ing] inner perimeter and gates”;



“Protect[ing] against unauthorized access”;



“early warning … of perimeter breaches”;


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

“Secur[ing] internal festival grounds”;



“Patrol[ing] festival floor grounds and assist[ing] patrons with any security

related issues”;


pre-event planning for “Security and Safety”;



“Emergency response” and “evacuation,” including evacuation for “terrorist

threat” and “ensur[ing] that the exit routes and gates remain unobstructed.”
58.

For the reasons set forth above, the SAFETY Act creates an exclusive cause

of action for any claims arising out of relating to Paddock’s mass attack and such claims may
result in loss to the Seller. Under the SAFETY Act, there “shall exist only one cause of
action for loss of property, personal injury, or death. 6 C.F.R. § 25.7 (d).
59.

Such cause of action “may be brought only against the Seller of the Qualified

Anti-Terrorism Technology and may not be brought against the buyers, the buyer’s
contractors, or downstream users of the Technology, the Seller’s suppliers or contractors, or
any other person or entity.” 6 C.F.R. 25.7 (d). The SAFETY Act precludes any liability on
the part of Plaintiffs to Defendants relating to Paddock’s mass attack.
60.

In addition, the SAFETY Act provides that for any covered claims arising out

of or relating to an act of mass violence where certified services were provided, “the
government contractor defense applies in such a lawsuit,” which provides a complete defense

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to liability. 6 U.S.C. § 442(d)(1). The government contractor defense precludes any finding
of liability on the part of Plaintiffs to Defendants relating to Paddock’s mass attack.
61.

An actual and justiciable controversy exists between Plaintiffs and Defendants

concerning the applicability of the SAFETY Act. Plaintiffs assert that the SAFETY Act
precludes any liability for any claims arising out of or relating to Paddock’s mass attack,
whereas, on information and belief, Defendants deny that the Act applies or that it precludes
liability on their claims against Plaintiffs.

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62.

A judicial declaration as to whether the SAFETY Act applies and precludes

liability on Defendants’ claims against the Plaintiffs is necessary at this time so that the
parties may ascertain their rights, and avoid the significant judicial waste that would occur if
the lawsuits were allowed to proceed in the absence of a finding as to the applicability of the
SAFETY Act.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs MGM Parties pray for judgment against Defendants, and
each of them, as follows:
1.

For a judicial declaration that:
a. Defendants’ claims arising from the attack by Stephen Paddock on October
1, 2017 in Las Vegas, Nevada are subject to and governed by the SAFETY
Act, 6 U.S.C. §§ 441 et seq.;
b. the SAFETY Act precludes any finding of liability against Plaintiffs for any
claim for injuries arising out of or related to Paddock’s mass attack, without
prejudice to Defendants’ rights to pursue claims against the “Seller” under
the Act, including to obtain proceeds of insurance that any such Seller was
required by the Act to maintain;
c. Plaintiffs have no liability of any kind to Defendants, or any of them, arising
from the Paddock’s mass attack; and

COMPLAINT FOR DECLARATORY RELIEF
MGM RESORTS INT’L et al. v. CORBIN et al.
Case No. 3:18-cv-00168-TMB
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2.

For such other and further legal or equitable relief as the Court deems just and

proper.
Respectfully requested,
DATED: July 17, 2018

WILSON ELSER MOSKOWITZ
EDELMAN & DICKER, LLP

WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
555 South Flower Street, Suite 2900
Los Angeles, CA 90071-2407

/s/ B. Otis Felder
E. Stratton Horres, Esq., (Pro Hac Vice Forthcoming)
B. Otis Felder, Esq., ABA #511081
[e-mail]
555 South Flower Street, Suite 2900
Los Angeles, California 90071
Tel: [phone] /Fax: [phone]
Attorneys for Plaintiffs
MGM RESORTS INTERNATIONAL,
MANDALAY RESORT GROUP,
MANDALAY BAY, LLC,
MGM RESORTS FESTIVAL GROUNDS, LLC, and
MGM RESORTS VENUE MANAGEMENT, LLC

COMPLAINT FOR DECLARATORY RELIEF
MGM RESORTS INT’L et al. v. CORBIN et al.
Case No. 3:18-cv-00168-TMB
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