Johnston v. One America Productions, Inc. et al

Filing 7

'',

Johnston v. One America Productions, Inc. et al

Doc. 7 Att. 1

Case 2:07-cv-00042-WAP-EMB

Document 7-2

Filed 06/20/2007

Page 1 of 3

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF MISSISSIPPI DELTA DIVISION
ELLEN JOHNSTON

i t;; . iF'" ff'

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ONE AMERICA PRODUCTIONS , INC. EVERYMAN PICTURES , TWENTIETH CENTURY- FOX FILM CORPORATION AND JOHN DOES 1 AND 2

DEFENDANTS

COMPLAINT
COMES NOW Plaintiff, Ellen Johnston, by and though
counsel,

Wiliam O. Luckett, Jr. of

Luckett Tyner Law Finn, P .
following:

, and files and seres this her Complaint for damages and states the

The Plaintiff Ellen Johnston,

is an adult resident

citizen of

Coahoma County,

Mississippi. Her residential address is 121 Ritch Street , Clarksdale, Mississippi, 38614.

Defendant One America Productions

Inc. is a Californa Corporation with a

Registered Agent at 421 Beverly Drive, Eighth Floor, Beverly Hils, California, 90212; Defendant

Everyan Pictures is a Californa Corporation with a Registered Agent at 1880 Century Park East
Suite 1600, Los Angeles, Californa, 90067; and Defendant Twentieth Century-Fox

Film

Corporation is a Delaware Corporation with a Registered Agent at 10201 West Pico Boulevard , Los

Angeles , Californa, 90035. The identity of John Does 1 and 2 are unown at ths time, but they
wil be provided

when and if they are identified.
Borat

That venue and jursdiction are proper in their Court that the movie
distrbuted nationwide ,
including distrbution and sales within this distrct.
The movie

has been
Borat

has

been screened in the Northern Distrct of Mississippi and is now available for purchase on DVD

EXHIBIT 1
Dockets.Justia.com

Case 2:07-cv-00042-WAP-EMB

Document 7-2

Filed 06/20/2007

Page 2 of 3

within the Norther District of Mississippi.

Defendants invaded Plaintiff s privacy by filming Plaintiff without her consent on
July 10
2005 with the full intent of using the footage in the movie

Borat and by showing her image

on screen.
Defendants portayed Plaintiff in a false light in that the movie Borat

shows the

Plaintiff with her ars raised above her head praising the Lord as Sacha Baron Cohen s character

Borat , mocks Plaintiff s religion by addressing the entire group of people on camera and pretending
to speak in tongue.

Plaintiff did not sign a release to appear in the fim

Borat.

She was led to believe that

Mr. Cohen s camera crew was filming a "religious documentar." Therefore, the film s producers
had no authority to show her in the film Borat.

The fiming took place in an interor settg

where

the Plaintiff had an expectation of privacy.
Defendants ' gross negligence constituted willful , wanton, and reckless disregard for

Ms. Johnston s right to privacy, for its own monetar profit. Defendants should be deterred ffom

repeating such egregious acts by imposition of compensatory and puntive

damages.

WHEREFORE , PREMISES CONSIDERED, Plaintiff seeks compensatory damages in the

amount of$100 000. 00 and punitive damages in the amount of$500 000. 00 against Defendants in
for damages in this matter.
THIS the

day of March, 2007

Case 2:07-cv-00042-WAP-EMB

Document 7-2

Filed 06/20/2007

Page 3 of 3

Respectfully Submitted ELLEN JOHNSTON

Isl Wiliam O. Luckett. Jr. O. LUCKETT, (MSB# 1487)
LUCKETT TYNER LAW FIRM, P.
143 Y AZOO AVENU

POST OFFICE DRAWER 1000 CLARKSDALE , MISSISSIPPI 38614 (662)624- 2591 (662)627- 5403