Charlie Sheen vs. Lorre and Warner Brothers, Demand For Jury Trial

Source:
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MARTIN D. SINGER (BAR NO. 78166)
PAUL N. SORRELL (BAR NO. 126346)
WILLIAM J. BRIGGS II (BAR NO. 144717)
LAVELY & SINGER PROFESSIONAL CORPORATION

2049 Century Park East, Suite 2400
Los Angeles, California 90067-2906
Telephone: xxxxx
Facsimile: xxxxx
Email: xxxxx

Attourneys for Plaintiffs CHARLIE SHEEN and 9th STEP PRODUCTIONS.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - WEST DISTRICT

CHARLIE SHEEN, an individual; and 9th STEP PRODUCTIONS, a California corporation,
 Plaintiffs,
v.
CHUCK LORRE, an individual; CHUCK LORRE PRODUCTIONS, INC., a California corporation;
WB STUDIO ENTERPRISES, INC., a Delaware corporation; and DOES 1 through 20, inclusive,
 Defendants.


CASE NO. SC111794

COMPLAINT FOR:
(1) INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS;
(2) INTENTIONAL INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE;
(3) BREACH OF CONTRACT;
(4) BREACH QF THE IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING;
(5) BREACH QF CONTRACT AS THIRD PARTY BENEFICIARY;
(6) RECOVERY OF UNPAID WAGES;
(7) VIOLATION OF CALIFORNIA LABOR CODE PRIVATE ATTORNEY GENERAL ACT;
(8) VIOLATION OF FEHA; AND
(9) RETALIATION

 
DEMAND FOR JURY TRIAL

Plaintiffs Charlie Sheen and 9th Step Productions (collectively
sometimes referred to as "Plaintiffs"), for their Complaint against
Defendants Chuck Lorre, Chuck Lorre Productions, Inc.  and WB Studio
Enterprises, Inc. (sometimes collectively referred to as "Defendants")
hereby allege as follows:


THE NATURE OF THIS ACTION

1. Defendant Chuck Lorre, one of the richest men in television who is
worth hundreds of millions of dollars, believes himself to be so
wealthy and powerful that he can unilaterally decide to take money
away from the dedicated cast and crew of the popular television series
Two and a Half Men (the "Series") in order to serve his own ego and
self-interest, and make the star of the Series the scapegoat for
Lorre's own conduct.

2. Notwithstanding that Warner Bros. and Lorre were able to generate
more than a billion dollars as a result of Charlie Sheen, the cast and
crew rendering services on the Series, Lorre and Warner Bros. decided
unilaterally not to pay Mr. Sheen or the other cast and the crew for
the remainder of this season. Weeks before Mr. Sheen publically
criticized Lorre, Warner Bros. and Lorre decided to cut the season four
weeks short. By this Complaint, Charlie Sheen is not only seeking
payment of his own compensation for the Series, but he is also
pursuing claims for the benefit of the entire cast and crew to get
paid for the balance of the season's 24 episodes.

3. Warner Bros. was quite happy to line its coffers and employ Charlie
Sheen as its star and the centerpiece of its successful prime time
lineup even while he was obtaining treatment in rehab, while he was
the subject of salacious gossip stories after he had been accused of
trashing a New York hotel room, and even while Mr. Sheen faced a
looming potential felony conviction. In fact, while the felony charges
were pending against Mr. Sheen and he was in rehab dealing with
substance abuse issues, Warner Bros. not only had no objection to
continuing to work with Mr. Sheen on the Series, it approached
Mr. Sheen to have him enter into a new contract to perform two
additional seasons of the Series. Warner Bros. entered into the
contract for Mr. Sheen to perform two additional seasons of the Series
while felony and misdemeanor charges were pending against
Mr. Sheen. Warner Bros. even stated that it would not object to
Mr. Sheen entering a guilty plea and having a convicted felon as its
Monday night star, so long as it would not unnecessarily interfere
with the production schedule. None of this resulted in Warner Bros,
suspending Mr. Sheen. What did?

4. After years of Lorre humiliating, harassing, and disparaging
Mr. Sheen, and after Lorre unilaterally decided not to write scripts
as required to complete the 2010/2011 season's contemplated episodes
of the Series, Mr. Sheen deigned to criticize Lorre. Warner
Bros. capitulated to Lorre's egotistical desire to punish Mr. Sheen
and to stop work on the Series for the rest of the season, and used
its powerful public relations machine to create a myth to justify
their conduct by wrongly blaming Mr. Sheen.

5. This action was necessitated by the wrongful interference with
actor Charlie Sheen's right to perform and receive compensation to
which he is contractually entitled from the popular prime time CBS
Series. Series Producer WB Studio Enterprises, Inc. (" Warner Bros."
or "WB") suspended production of the Series, and breached Mr. Sheen's
contract not due to actions by Mr. Sheen as Defendants are trying to
claim, but in order to placate the massive ego and selfish demands of
the co-creator and show runner, Defendant Chuck Lorre.  Because of his
financial leverage with Warner Bros. and CBS by having two other
profitable series with them, Lorre convinced Warner Bros. to conspire
with him and attribute the suspension of the Series and termination of
Mr. Sheen's contract on Mr. Sheen's alleged statements, conduct and
condition, despite the fact that Mr. Sheen is in compliance with his
contract and ready, willing and able to proceed. Moreover, even if the
stated grounds for terminating Mr. Sheen's contract actually existed
(which Mr. Sheen denies), Warner Bros.' actions would under the
circumstances constitute wrongful termination and unlawful retaliation
in violation of California law.

6. Charlie Sheen has been lining Lorre's and Warner Bros. pockets with
what will amount to billions of dollars through Mr. Sheen's work on
177 episodes on the Series, and Mr. Sheen had been ready, willing and
able to continue to work to finish out the season. Although Mr. Sheen
was scheduled to return to work on February 14, 2011 as requested, he
was subsequently told that no scripts were available for
shooting. Lorre unilaterally decided not to write scripts as required
for the full order of contemplated episodes of the Series. (CBS
ordered 24 episodes of the Series for the 2010/2011 season. Mr. Sheen
has been informed that by February 14, 2011, Lorre had delivered only
16 episodes.) Indeed, Lorre failed to work on
and produce shooting scripts so that the production could commence on
February 14, 2011, and then along with Warner Bros unilaterally
truncated the production schedule and indicated that no episodes would
be produced after March 25, 2011 (for a total of four additional
episodes despite the fact that there was obviously time to produce at
least six if not eight more episodes before the schedule completion of
production). Why? The decision to shut down the Series early by
Lorre, acquiesced to by Warner Bros. and Mr. Sheen, occurred prior to
any public criticism of Lorre by Sheen.

7. Since Lorre has a better deal and stands to make even more money on
his other current shows The Big Bang Theory and Mike & Molly if they
flourish, Lorre has been motivated in part by his own self interest
and conflict of interest to make his other shows flourish at the
expense of the Series and because of his animus toward Mr. Sheen. To
justify Lorre's conduct, Lorre and Warner Bros, conspired to conjure
up a pretext to first prematurely end the Series on March 25, and
subsequently suspend and then terminate Mr. Sheen, creating a public
relations fiction to make him their scapegoat despite the fact that
Mr. Sheen was sober, and was ready, willing and able to perform.

8. Yet, at a time when both felony aud misdemeanor charges were
pending against Mr. Sheen, Warner Bros. actively pursued Mr. Sheen and
negotiated a new deal with him as of May 2010 for Mr. Sheen to perform
in the Series for two additional seasons. Warner Bros.  did not
suspend Mr. Sheen while felony charges loomed; to the contrary, the
production company was keen to persuade him to commit to work for two
additional seasons on the Series, even if it meant that a convicted
felon would be starring in the Series, since it would add to the
billions that could ultimately be reaped by Warner Bros. and Lorre
from Mr. Sheen's work. In fact, Warner Bros. had pursued Mr. Sheen to
appear in the Series fur an additional two years, since he had
initially been uninterested in continuing for an additional two years
unless he received appropriate compensation to do so.

9. The suspension and termination of Mr. Sheen occurred only after
Mr. Sheen had finally been provoked into criticizing Lorre in response
to his harassment and disparagement campaign which had been going on
for years. It was no coincidence that the
suspension and termination of Mr. Sheen occurred only after Mr. Lorre
had himself failed to write scripts needed to do the season's
remaining episodes.

10. Significantly, Warner Bros, suspension and termirmtion of
Mr. Sheen came after he had undergone private rehab treatment at
Warner Bros.' request (performed at Mr. Sheen's home to ensure his
privacy) with a cadre of experts who included the expert recommended
by Mr. Lorre himself. When Mr. Sheen was sober, and had passed several
drug tests, and was ready, willing and able to return to work, he was
told "No." Yet, although Warner Bros.  stands to make over $1 billion
as a result of Mr. Sheen's work on the Series, it is retaliating
against him by not only suspending and terminating him, but by also
refusing to pay his "pay or play" salary and back end compensation in
anticipatory breach of its contractual obligations.  Warner Bros. has
anticipatorily repudiated its contractual obligations to Plaintiff to
pay Mr. Sheen's salary and back end on the Series despite the fact
that Mr. Sheen faithfully and fully performed on 177 episodes.

11. Thus, not only has Warner Bros. pulled the plug on the episodes
remaining for the 2010-2011 season thereby putting the crew and cast
including Mr. Sheen out of work, it is retaliating against Mr. Sheen
by refusing to pay his remaining guaranteed salary together with his
back end in anticipatory breach of its contractual obligations.

12. In fact, apparently not satisfied with just attempting to renege
on paying Mr.  Sheen his remaining guaranteed salary and the back end
compensation he earned through his hard work on 177 episodes, Warner
Bros. has gone even further in its retaliatory attempts to punish
him. Despite the fact that Warner Bros., Lorre, and CBS will earn
billions of dollars from Mr. Sheen's work, Warner Bros. has the
temerity to indicate that Mr. Sheen ought to pay Warner Bros. hundreds
of millions of dollars.

13. In first announcing that production of the Series would be
discontinued for the remainder of the 2010/2011 season, and then
subsequently announcing that Mr. Sheen had been terminated, Warner
Bros. and CBS sought to satisfy Lorre's wrongful and overreaching
demands. They did so because of Lorre's significant influence upon
them as a result of his role as creator of multiple prime time
television programs from which Warner Bros. and CBS
reap huge profits. Lorre is the proverbial "800-pound gorilla" as far
as WB and CBS are concerned. Unfortunately, in this instance the
capitulation to Lorre's demands - fueled by Lorre's inflated ego,
laziness and ill-will toward Mr. Sheen and his perceived lifestyle -
is in direct derogation of Mr. Sheen's rights. This dispute is not the
first time that Lorre has had problems working with major television
stars, including Roseanne Barr, Cybill Shepherd, and Brett Butler.

14. Defendants' actions in furtherance of their wrongful conspiracy
have resulted in substantial damages not only to Plaintiffs, but to
numerous innocent, hardworking cast and crew members whose welfare
Defendants callously ignore. The recent attempt to termitmte
Mr. Sheen's contract is nothing more than a transparent attempt to
avoid the obligation to pay him for a minimum number of episodes under
his "pay or play" contract, and a clear violation of California
law. Defendants are responsible to compensate the parties who have
suffered as a result of their actions in an amount believed to exceed
$100 million, as well as to pay substantial punitive damages to
prevent Defendants from engaging in such conduct in the
future. Charlie Sheen brings this action on his behalf, as well as the
other cast and crew of the Series, in an attempt to partially rectify
the serious injustice that Defendants' wrongful conduct has created.

15. Through this action, Mr. Sheen is seeking compensation to which he
is contractually entitled and which he has earned through his hard
work contributing to the tremendous success of the Series. He also
seeks to remedy the harm Defendants are causing to the crew and cast
who have been damaged by Defendants' callous and self-serving conduct.


THE PARTIES TO THE ACTION

16. Plaintiff Charlie Sheen is an individual who resides and conducts
business in the County of Los Angeles. Mr. Sheen is an actor and star
of the Series.

17. Plaintiff 9th Step Productions is a corporation duly organized and
existing under the laws of the State of California with its principal
place of business in Los Angeles County, and is a loan-out corporation
formed by Charlie Sheen to contract out his acting services on the
Series. (Plaintiffs Charlie Sheen and 9th Step productions are
sometimes collectively hereinafter referred to as "Plaintiffs" )

18. Plaintiffs are informed and believe and thereon allege that
Defendant Chuck Lorre, whose real name on information and belief is
Charles Michael Levine ("Lorre"), is an individual who resides in West
Los Angeles and conducts business in Los Angeles County, California,
and is a principal of Defendant Chuck Lorre Productions, Inc. Lorre is
the cocreator and Executive Producer of the Series.

19. Plaintiffs are informed and believe and thereon allege that
Defendant (Chuck Lorre Productions, Inc. ("CLPI") is and at all
times relevant hereto was a corporation duly organized and existing
under the laws of the State of California with its principal place of
business in Los Angeles County, and that CLPI primarily conducts its
business from offices on the lot of Defendant WB.

20. Plaintiffs are informed and believe and thereon allege that
Detendant WB Studio Enterprises Inc. ("WB") is and at all times
relevant hereto was a corporation duly organized and existing under
the laws of the State of Delaware, and regularly conducts business in
Los Angeles County. Plaintiffs are further informed and believe and
thereon allege that WB has contracted with Plaintiff 9th Step
Productions for Mr. Sheen's acting services on the Series through its
division "Warner Bros. Television."

21. Plaintiffs are informed and believe and thereon afiege that the
fictitiously-named Defendants sued herein as Does 1 through 20,
inclusive, and each of them, are in some manner responsible for the
occurrences, acts and omissions alleged herein and that Plaintiffs'
damages were proximately caused by their conduct. The true names and
capacities of such fictitiously-named Doe Defendants, whether
individual, corporate, partnership, associate or otherwise, are
presently unknown to Plaintiffs, and Plaintiffs will seek leave of
Court to amend this Complaint to assert the true names and capacities
of such fictitiously-named Defendants when the same have been
ascertained. For convenience, each reference to any of the named
Defendants herein shall also refer to Does 1 through 20, inclusive.

22. Plaintiffs are informed and believe and thereon allege that
Defendants, and each of them, were and are the agents, employees,
partners, joint venturers, co-conspirators, owners, principals and/or
employers of the remaining Defendants, and at all times herein
mentioned were and are acting within the course and scope of such
agency, employment, partnership, conspiracy, ownership and/or joint
venture. Plaintiffs are further informed and believe and based thereon
allege that the acts and conduct herein alleged of each such Defendant
were known to, authorized by and/or ratified by the other Defendants,
and each of them.


THE BASIC FACTS LEADING TO THIS DISPUTE

23. As of May 17, 2010, Plaintiff 9th Step Productions entered into a
written letter agreement with WB, through a division of WB called
Warner Bros. Television, for the acting services of Plaintiff Charlie
Sheen with respect to the 2010/2011 and 2011/2012 production seasons
of the Series (the "Acting Agreement" ). The Acting Agreement provides
for, among other things, payment to 9th Step Productions of a
specified fee per episode for Mr. Sheen's acting services, on a "pay
or play" basis, with a minimum guarantee of 24 episodes per
season. The Acting Agreement incorporated provisions from previous
written agreements relating to earlier seasons of the Series.

24. Plaintiffs are informed and believe and thereon allege that
Defendants Lorre and/or CLPI have also entered into an agreement with
WB pursuant to which Defendants agreed to act as show runner and to
timely write and develop scripts for episodes of the Series, in which
it was always contemplated that Charlie Sheen would star pursuant to
the Acting Agreement (the "Show Runner Agreement" ). The Show Runner
Agreement was entered into expressly for the benefit of Plaintiffs in
that, among other things, the services of both Mr. Sheen and Lorre
were necessary in order for the Series to succeed. It was necessary
for Lorre to fully and timely discharge the obligations specified in
the Show Runner Agreement in order for both WB and Plaintiffs to
obtain the rights and benefits of, and to properly discharge their
respective obligations under, the Acting Agreement.

25. In early February 2011, production of the Series was briefly
postponed due to Mr. Sheen's hospitalization. On February 14, 2011,
Mr. Sheen attempted to return to the set in accordance with the agreed
production schedule. However, he was informed that production could
not proceed because Lorre had not supervised or arranged for
production of shooting scripts, notwithstanding the fact that it was
contemplated that Mr. Sheen would return shortly to work. Mr. Sheen
was informed that he should return to work the week of February 28,
2011, when production of the Series would resume.

26. The conduct of Lorre, on his own behalf and on behalf of CLPI, in
refusing to arrange for production of shooting scripts for the Series
so that production could be continued in mid-February, 2011 was a
unilateral breach of the Show Runner Agreement, as well as a direct
interference with the Acting Agreement. Lorre had no right to
unilaterally discontinue the production of shooting scripts, and
thereby interrupt the production schedule. His conduct, moreover,
significantly damaged not only Plaintiffs but the crew and other cast
members working on the Series. Plaintiffs are informed and believe and
thereon allege that Defendants Lorre and CLPI took this action to
satisfy their own egotistical desires and damage Mr. Sheen.

27. Even with postponing production until the delayed February 28,
2011 date, there was still adequate time under the agreed production
schedule (which was to terminate on or about April 8, 2011) to
complete an additional six to eight episodes of the Series under the
original production schedule and the Acting Agreement. However, in
mid-February, 2011, Plaintiffs were informed that the production
schedule would arbitrarily be terminated on or about March 25, 2011,
and that only four additional episodes of the Series would be produced
under the revised schedule. This arbitrary determination, which
Plaintiffs are informed and believe and thereon allege was at the
urging and insistence of Defendants Lorre and CLPI and agreed to by
Defendant WB, constituted a breach by WB, and an unlawful and
intentional interference by Defendants Lorre and CLPI, of Plaintiffs'
rights under the Acting Agreement.  Once again, this action also
adversely affected numerous innocent people working on the Series
including the cast and crew.

28. From time to time during the production of the Series, Defendant
Chuck Lorre, on his own behalf and on behalf of Defendant CLPI,
engaged in conduct and made statements to Mr. Sheen and publicly to
others, including the media, in order to intentionally harass, annoy
and damage Plaintiffs. For no legitimate reason whatsoever, Lorre
required Mr. Sheen to perform multiple takes of scenes during filming
solely to harass and frustrate Mr. Sheen and exhibit that Lorre was in
control. Lorre also engaged in a pattern and practice of disseminating
harassing, derogatory and highly inflammatory comments about Mr. Sheen
through the media and through the use of "vanity cards" broadcast at
the end of each episode of the Series.

29. Among the numerous harassing, derogatory and damaging statements
that Defendants Lorre and CLPI have publicly disseminated via the
internationally broadcast vanity cards that obviously refer to
Mr. Sheen are the following:

Under the heading "To Do List," Lorre wrote "Meditate using new
mantra, 'High ratings do not equate to high self-esteem,'" "Go to
Al-Anon meeting," and "Write a country song entitled, 'Hooker in the
Closet.' (Chorus: 'There's a hooker in the closet, 'neath the
monogrammed robes, don't know how she got there and I can't find my
clothes. Officer Krupke, how are you tonight? I've misplaced my watch
but I'm feeling alright.')"

Following statements about his own healthy lifestyle, Lorre wrote: If
Charlie Sheen outlives me, I'm gonna be really pissed."

Lorre suggested that persons viewing the show not drink to excess and
"avoid degrading yourself by having meaningless sex with strangers in
a futile attempt to fill the emptiness in your soul."

Lorre suggested that the audience extend prayers to people working on
the Series and that viewers should "Feel free to pick whomever you
think is most in need. Just hurry."

He also wrote, "We employ a highly-paid Hollywood professional who has
years of experience with putting his life at risk. And sadly no, I'm
not talking about our stunt man."

30. When Mr. Sheen finally responded to Lorre's unrelenting derogatory
statements in the media during the week of February 21, 2011,
Defendants Lorre and CLPI retaliated by using their influence to
prevail upon WB to terminate production of the Series for the
remainder of the 2010/2011 Season. On or about February 24, 2011, WB
and CBS issued the following joint statement; "Based on the totality
of Charlie Sheen's statements, conduct and condition, CBS and Warner
Bros. Television have decided to discontinue production of Two and a
Half Men for the remainder of the season." On March 7, 2011,
Plaintiffs were informed that WB terminated the Acting Agreement and
does not intend to pay Plaintiffs the compensation due thereunder.

31. Notwithstanding the attempt to premise the cancellation of
production of the Series and the termination of the Acting Agreement
upon Mr. Sheen's alleged conduct, including his response to the
campaign of harassment and derogatory statements by Lorre about
Mr. Sheen in the media, Defendants Lorre and CLPI had already refused
to perform their obligations under the Show Runner Agreement by, among
other things, (a) refusing to supervise production of shooting scripts
in January and February in anticipation of Mr. Sheen's imminent
return to the set, and (b) demanding that production of the Series
terminate on March 25 instead of April 8, 2011, long before Mr. Sheen
made any public statements about Lorre. The lack of merit in
Defendants' attempt to premise termination of production of the Series
and the Acting Agreement upon Mr. Sheen's alleged statements, conduct
and condition is further evidenced by the fact that all of the parties
involved in production of the Series, including Defendants, were fully
prepared to proceed with Mr. Sheen in a starring role on the Series -
and in fact WB negotiated and entered into a new contract with
Mr. Sheen - in 2010 at a time when Mr. Sheen was facing potentiial
felony charges and jail time. At that time, Mr. Sheen was informed
that his involvement with the Series would not be jeopardized even it
he pleaded guilty to a felony and served jail time, as long as he was
available to perform his
obligations under the Acting Agreement. Although WB attempted to
attribute termination of the Acting Agreement to Mr. Sheen's failure
to perform his contractual obligations, Mr. Sheen had performed his
acting services flawlessly on episodes filmed shortly before the
alleged termination, including episodes filmed before a live audience,
and received no complaints about his performance at any time prior to
his statements about Defendants in the press during the week of
February 21, 2001, shortly before Defendants terminated production of
the Series.

32. Plaintiffs are informed and believe and thereon allege that the
actions of Defendants Lorre and CLPI as alleged herein were fueled not
only by Lorre's ego, but also by a material conflict of interest
between the involvement of Lorre and CLPI on the Series and their
other projects at Warner Bros. and CBS. Among other things, Plaintiffs
are informed and believe that Lorre and CLPI have a significantly
higher profit participation on their other projects at WB and CBS than
they do on the Series, and that writers who they originally hired to
work on the Series are now writing for their other shows, such that
they were incentivized to focus on their other shows as opposed to
continuing their involvement on the Series as required under the Show
Runner Agreement.

33. Plaintiffs are informed and believe and thereon allege that WB has
permitted Defendants Lorre and CLPI to refuse to work and breach the
Show Runner Agreement, without taking any contractual or disciplinary
action against them, and has permitted Lorre and CLPI to interfere
with Plaintiffs' rights under the Acting Agreement, because of the
lucrative business relationship between WB and CBS, on the one hand,
and Defendants Lorre and CLPI, on the other hand. Among other things,
Defendants Lorre and CLPI are currently in production on at least
three separate prime time television programs that air on CBS and are
produced under the WB studio banner. Defendants Lorre and CLPI in fact
maintain offices on the WB lot. Because of the close and very
lucrative business relationship between Defendants Lorre and CLPI, on
the one hand, and Defendant WB and CBS, on the other hand, Defendants
conspired with each other in breaching the obligations owed to
Plaintiffs under the Acting Agreement, and in tortiously interfering
with Plaintiffs' rights. Plaintiffs are entitled to recover
significant compensatory and punitive damages, as well as costs and
attorneys fees
incurred in enforcing their rights as recoverable under the Acting
Agreement and other amounts as a result of this conduct.


FIRST CAUSE OF ACTION

(By Plaintiff 9th Step Productions for Intentional Interference With
Contractual Relations Against Defendants Lorre and CLPI)

34. Plaintiffs incorporate herein by reference each and every
allegation contained in Paragraphs 1 through 33, inclusive, of this
Complaint as if fully set forth herein.

35. At all relevant times, Defendants Lorre and CLPI knew of the
existence of the Acting Agreement between Plaintiff 9th Step
Productions and WB as described above.

36. The participation of Defendants Lorre and CLPI, the show runner
for the Series, is critical to the production of the Series. Because
of this, and the lucrative business relationship that they share with
WB and CBS, Defendants Lorre and CLPI knew at all relevant times that
neither WB nor CBS would proceed with the production of Series
episodes without their involvement.

37. Plaintiffs are informed and believe and thereon allege that, in an
effort to interfere with Plaintiffs rights under the Acting Agreement,
Defendants Lorre and CLPI, beginning in late January 2011 when Sheen
was briefly hospitalized, failed and refused to arrange for the
production of shooting scripts for the Series notwithstanding that it
was anticipated that Mr. Sheen would shortly return to work. When
Mr. Sheen attempted to return for filming on February 14, 2011, he was
informed that production would not be proceeding at that time because
of the unavailability of scripts. Subsequently, Mr. Sheen was informed
that he should return to work on or about February 28, 2011, but that
there would be an early termination of the production schedule for the
Series, so that production would be completed on or about March 25,
2011 instead of April 8, 2011. Plaintiffs are informed and believe and
thereon allege that this early termination date was unilaterally
imposed by Defendants Lorre and CLPI, who refused to participate in
the production of any episodes of the Series beyond the March 25, 2011
date. Plaintiffs are further informed and believe and thereon allege
that
during the week of February 21, 2011, Defendants Lorre and CLPI stated
that they would not participate in any further episodes of the Series
during the 2010/2011 season, and ultimately persuaded WB and CBS to
terminate any further production of the Series and to breach the
obligations owed to Plaintiff 9th Step Productions under the Acting
Agreement. WB has indicated that it does not intend to pay further
episodic payments or other amounts due to Plaintiff 9th Step
Productions under the Agreement.

38. Defendants Lorre and CLPI engaged in the conduct alleged herein
with the intent to harm plaintiff 9th Step productions and its
beneficiaries financially and to induce WB to violate the Acting
Agreement, and/or to make the contractual relationship between WB and
Plaintiffs less financially lucrative to Plaintiffs.

39. As a proximate result of the conduct of Defendants Lorre and CLPI
as alleged herein, Plaintiff 9th Step Productions was damaged in an
amount in excess of One Hundred Million Dollars, the exact amount of
which will be proven at time of trial. When Plaintiff has ascertained
the full amount of its damages, it will seek leave of Court to amend
this Complaint accordingly.

40. The conduct of Defendants Lorre and CLPI as alleged herein was
purposeful and intentional and was engaged in for the purpose of
depriving Plaintiffs of property or legal rights or otherwise causing
injury, and was despicable conduct that subjected plaintiff 9th Step
Productions to cruel and unjust hardship in conscious disregard of
its rights, and was performed with fraud, oppression or malice so as
to justify an award of exemplary or punitive damages against such
Defendants in an amount according to proof at trial.


SECOND CAUSE OF ACTION

(By Plaintiffs Charlie Sheen and 9th Step Productions for Intentional
Interference With Prospective Economic Advantage Against Defendants
Lorre and CLPI)

41. Plaintiffs incorporate herein by reference each and every
allegation contained in Paragraphs 1 through 33, inclusive, of this
Complaint as if fully set forth herein.

42. Prior to engaging in the aforementioned conduct, Defendants Lorre
and CLPI were fully aware that Plaintiffs had business relationships
with WB and CBS which were very likely to result in
economically-advantageous relationships between Plaintiffs, WB and
CBS.  Plaintiffs are informed and believe and thereon allege that, in
addition to the relationship between Plaintiffs, on the one hand, and
WB and CBS, on the other hand, with respect to the Series, Defendants
Lorre and CLPI were aware that Charlie Sheen had a right of first
look/first negotiation agreement with WB concerning literary
properties that might be developed by or on behalf of Mr. Sheen.

43. Defendants Lorre and CLPI engaged in the conduct alleged above
with the intent to interfere with and/or destroy the
economically-advantageous relationships between Plaintiffs, on the one
hand, and WB and CBS, on the other hand, and to make those
relationships less financially lucrative for Plaintiffs. The conduct
of these Defendants was independently wrongful because, among other
things, Defendants were engaging in unlawful retaliation prohibited by
the Fair Employment and Housing Act after Plaintiff Charlie Sheen
attempted to defend himself against Defendants' harassment.

44. As a proximate result of the conduct of Defendants Lorre and CLPI
as alleged herein, Plaintiffs have been damaged in an amount in excess
of One Hundred Million Dollars, the exact amount of which will be
proven at the time of trial. When Plaintiffs have ascertained the full
amount of their damages, they will seek leave of Court to amend this
Complaint accordingly.

45. The conduct of Defendants Lorre and CLPI as alleged herein was
purposeful and intentional and was engaged in for the purpose of
depriving Plaintiffs of property or legal rights or otherwise causing
injury, and was despicable conduct that subjected Plaintiffs to cruel
and unjust hardship in conscious disregard of its rights, and was
performed with fraud, oppression or malice so as to justify an award
of exemplary or punitive damages against such Defendants in an amount
according to proof at trial.


THIRD CAUSE OF ACTION

(By Plaintiff 9th Step Productions for Breach of the Acting Agreement
Against Defendant WB)

46. Plaintiffs incorporate herein by reference each and every
allegation contained in Paragraphs 1 through 33, inclusive, of this
Complaint as if fully set forth herein.

47. Pursuant to the Acting Agreement between Plaintiff 9th Step
Productions and WB, 9th Step is entitled to be paid for Mr. Sheen's
services on the Series on a pay-or-play basis at a specified rate per
episode, with a minimum guarantee of 24 episodes per production
season. In addition, plaintiff 9th Step productions is entitled to be
paid back end compensation and other amounts speclfied in the Acting
Agreement.

48. Plaintiffs are informed and believe that WB intends to pay 9th
Step Productions for a maximum of 16 episodes for the 2010/2011 season
of the Series, and in any event does not intend to pay the episodic
fee for a minimum of 24 episodes as required under the Acting
Agreement. WB has also stated that it is refusing to pay the back end
compensation and other amounts due and owing to Plaintiff under the
Acting Agreement. WB's conduct in refusing to pay the episodic fees
owed under the Acting Agreement constitutes a breach of the Acting
Agreement, and its statements indicating that it does not intend to
pay the back end compensation due and owing to 9th Step despite the
fact that Plaintiffs have faithfully rendered services and fully
performed their obligations on 177 episodes of the Series constitutes
an anticipatory breach of the Acting Agreement.

49. Plaintiffs have performed all conditions, covenants and promises
required pursuant to the Acting Agreement, except for those
conditions, covenants and promises which have been prevented or
otherwise excused by WB's conduct.

50. WB has materially breached the Acting Agreement by, among other
things, failing and refusing to pay the episodic fee payments for 24
episodes of the Series and other payments, including back end
compensation required under the Acting Agreement.

51. As a proximate result of WB's breaches of contract, Plaintiff 9th
Step Productions has sustained damages in an amount in excess of One
Hundred Million Dollars,
together with interest thereon at the maximum legal rate. In addition,
the Acting Agreement provides for recovery of "all costs, fees and
expenses, including attorneys fees" incurred in enforcing an award
obtained pursuant to the Acting Agreement. Plaintiff seeks those
amounts as well. When Plaintiff has ascertained the full amount of its
damages, it will seek leave of Court to amend this Complaint
accordingly.


FOURTH CAUSE OF ACTION

(By Plaintiff 9th Step Productions for Breach of the Implied Covenant
of Good Faith And Fair Dealing Against Defendant WB)

52. Plaintiffs incorporate herein by reference each and every
allegation contained in Paragraphs 1 through 33, and 47 through 50,
inclusive, of this Complaint as if fully set forth herein.

53. Implied in every contract is a covenant of good faith and fair
dealing that neither party will engage in any act or omission that is
intended or has the natural tendency to deprive the other party of the
full benefits of its bargain. This covenant is implied into the Acting
Agreement, and imposes upon WB a duty not to engage in acts or
omissions that would frustrate the enjoyment of plaintiff 9th Step
productions of any of the rights and benefits owed or reasonably
expected under the Acting Agreement.

54. By virtue of the relationship between Plaintiffs, on the one hand,
and WB and its division Warner Bros. Television, on tbe other hand,
Plaintiffs have placed trust and confidence in WB to perform all the
duties aad obligations owed and reasonably expected pursuant to the
terms of the Acting Agreement and to honor the implied covenant to act
in good faith and not to take any action which would unduly or
unreasonably impair or harm any rights or benefits owed or reasonably
expected under the Acting Agreement.

55. WB has breached the implied covenant of good faith and fair
dealing and denied Plaintiff 9th Step Productions and its
beneficiaries the rights and benefits to which they are entitled or
reasonably expected under the Acting Agreement by engaging in the
aforementioned conduct and by permitting and conspiring with
Defendants Lorre and CLPI in interfering with
and frustrating the purpose of the Acting Agreement and preventing
Plaintiffs from receiving the benefits reasonably expected under the
Acting Agreement, including payment of the episodic fees and back end
compensation contemplated in the Acting Agreement. Plaintiff 9th Step
Productions is informed and believes and thereon alleges that WB
pursued this course of conduct in bad faith and with the intent to
interfere with, injure and frustrate the enjoyment of the benefits and
rights conferred upon 9th Step Productions pursuant to the terms of
the Acting Agreement.

56. Even if and to the extent that WB's conduct did not constitute a
breach of the express contractual terms in the Acting Agreement, WB's
conduct as alleged herein has unfairly frustrated the agreed common
purposes of the Acting Agreement and has disappointed the reasonable
expectations of Plaintiff 9th Step Productions and its beneficiaries,
and deprived Plaintiff 9th Step Productions of the benefits reasonably
expected under the Acting Agreement.

57. As a proximate result of the breaches of the covenant of good
faith and fair dealing inherent in the Acting Agreement by WB,
Plaintiff 9th Step Productions has been damaged in an amount in excess
of One Hundred Million Dollars. When Plaintiff has ascertained the
full amount of its damages, it will seek leave of Court to amend this
Complaint accordingly.


FIFTH CAUSE OF ACTION

(By Plaintiffs Charlie Sheen and 9th Step Productions for Breach of
Contract [As Third Party Beneficiary of the Show Runner Agreement]
Against Defendants Lorre and CLPI)

58. Plaintiffs incorporate herein by reference each and every
allegation contained in Paragraphs 1 through 33, inclusive, of this
Complaint as if fully set forth herein.

59. Plaintiffs were and are expressly intended beneficiaries of the
Show Runner Agreement entered into between WB, on the one hand, and
Defendants Lorre and/or CLPI, on the other hand. Plaintiff Charlie
Sheen's involvement in the Series was essential to the purpose for
which the Show Runner Agreement was entered into. The Show Runner
Agreement was
entered into expressly for the benefit of Plaintiffs in that, among
other things, the services of both Plaintiff Charlie Sheen and
Defendant Chuck Lorre were necessary in order for the Series to go
forward and be successful, as it had been previously, and it was
necessary to retain Defendants' services and for Defendants to timely
perform their obligations under the Show Runner Agreement, for both
Plaintiffs and WB to obtain the rights and benefits of, and to
properly discharge their obligations under, the Acting
Agreement. Plaintiffs are, therefore, entitled to enforce Defendants'
obligations under the Show Runner Agreement as third party
beneficiaries of that contract.

60. Plaintiffs are informed and believe that Defendants' conduct as
alleged above constitutes a breach of the Show Runner Agreement.

61. Plaintiffs have performed all conditions, covenants and promises
contractually required of them in connection with the Series, except
for those conditions, covenants and promises that have been excused.

62. As a proximate result of Lorre's and CLPI's breaches of the Show
Runner Agreement, Plaintiffs have sustained damages in an amount to be
proven at trial, but which exceeds the jurisdictional minimum of this
Court, together with interest thereon at the maximum legal rate. Among
other things, Plaintiffs are informed and believe that WB intends to
pay 9th Step Productions for a maximum of 16 episodes for the
2010/2011 season of the Series because of Defendants' conduct, and in
any event does not intend to pay the guaranteed episodic fee for a
minimum of 24 episodes. WB has also refused timely to pay back end
compensation and other amounts due and owing under the Acting
Agreement. When Plaintiffs have ascertained the full amount of their
damages, they will seek leave of Court to amend this Complaint
accordingly.


SIXTH CAUSE OF ACTION

(By Plaintiffs Charlie Sheen and 9th Step Productions for Recovery of
Unpaid Wages Against Defendant WB)

63. Plaintiffs incorporate herein and by reference each and every
allegation contained in Paragraph 1 through 33, inclusive, of this
Complaint as if fully set forth herein.

64. Pursuant to the Acting Agreement between Plaintiff 9th Step
Productions and WB, WB is required to pay Plaintiff Charlie Sheen for
his Acting Services on the Series on a "pay or play" basis at a
specified rate per episode, with a minimum guarantee of 24 episodes
per production season. In addition, Plaintiff Charlie Sheen through
Plaintiff 9th Step Productions is entitled to be paid back-end
compensation and other amounts specified in the Acting Agreement.

65. Effective as of March 7, 2011, WB gave notice that it was
terminating Mr. Sheen's services on the Series and his Acting
Agreement. Plaintiffs are informed and believe that WB intends to pay
Charlie Sheen for only a maximum of 16 episodes for the 2010-2011
season of the Series, and WB does not intend to pay Charlie Sheen the
episodic fee for a minimum of 24 episodes as required under the Acting
Agreement. WB has also refused to timely pay the back-end compensation
and other amounts due and owing to Plaintiff under the Acting
Agreement.

66. Plaintiffs are further informed and believe that when WB notified
Mr. Sheen that it was terminating his Acting Agreement, the WB failed
and refused to pay all cast and crew on the Series for the minimum
guarantee of 24 episodes for the 2010-2011 season of the Series. Thus,
the WB intentionally deprived cast and crew members of the Series of
their wages for at least eight episodes (8) of the Series.

67. At the time the WB terminated Mr. Sheen, WB failed to pay the
Plaintiffs all amounts due and owing under the Acting Agreement. WB's
failure to pay the full amount due to Plaintiffs on termination
violates the provisions of Labor Code § 201. There is now due and
owing to Plaintiffs a sum in an amount to be proven at
trial. Defendants have failed and refused, and continue to fail and
refuse, to pay Plaintiffs' wages.

68. Additionally, at or about the time the WB terminated Mr. Sheen,
Mr. Sheen is informed and believes that WB failed to pay wages to the
cast and crew for at least 8 episodes of the Series. Defendants'
failure to pay the full amounts due to the cast and crew upon
termination of Plaintiffs' Acting Agreement violates the provisions of
Labor Code § 201.  There is now due and owing to members of the cast
and crew of the Series a sum to be proven at trial. Defendants have
failed and refused, and continue to fail and refuse, to pay the amount
due to the cast and crew. Pursuant to Labor Code § 2698, Plaintiff
Charlie Sheen asserts these claims on behalf of all of the aggrieved
cast and crew members who have not been paid by the WB and he intends
to formally lodge written notice with the Labor and Workforce
Development Agency as prescribed by Labor Code § 2699.3.

69. Pursuant to Labor Code §§ 218.5 and 2699 et al., Plaintiffs
request the Court award Plaintiffs reasonable attorneys' fees and
costs incurred by them in this action. Pursuant to Labor Code § 203,
Plaintiff requests that the Court award penalties and interest against
WB for its willful failure to pay wages of an employee who is
discharged.


SEVENTH CAUSE OF ACTION

(Violation of California Labor Code Private Attorney General Act
Against Defendant WB)

70. Plaintiffs incorporate herein and by reference each and every
allegation contained in Paragraph 1 through 33, inclusive, of this
Complaint as if fully set forth herein.

71. Mr. Sheen submits this claim to include allegations pursuant to
Labor Code §§ 2698 et seq. (The Private Attorney General
Act). Mr. Sheen intends to comply with all of the administrative
requirements listed in Labor Code § 2699.3 by giving notice to
Defendants and the Labor and Workforce Development Agency ("LWDA") of
the violations alleged herein and the theories and facts supporting
those allegations, and by anticipation of the LWDA's intention not to
investigate.

72. Mr. Sheen on his own behalf as well as on behalf of
similarly-situated current and former employees of WB on this Series,
brings this cause of action on behalf of himself
and the similarly-situated current and former employees of the Series
and the State of California concerning the WB's failure to pay wages
upon termination of Mr. Sheen and the penalties accruing to the State
of California as a result of the WB's treatment of all of its current
and former aggrieved employees.

73. Mr. Sheen seeks penalties of violations of the Labor Code that
provide for penalties pursuant to Labor Code § 2699(a). Mr. Sheen also
seeks penalties for violations of Labor Code provisions that do not
provide a penalty pursuant to Labor Code § 2699(f), which provides:

 For all provisions of this Code except those for which a civil penalty
 is specifically provided, there is established a civil penalty for
 violation of these provisions, as follow: ...(2) if, at the time of
 the alleged violation, the person employs one or more employees, the
 civil penalty is one hundred dollars ($100) for each aggrieved
 employee per pay period for the initial violation, and two hundred
 dollars ($200) for each aggrieved employee per pay period for each
 subsequent violation.

74. Mr. Sheen also seeks civil penalties as provided under applicable
Labor Code sections for violations of the Labor Code alleged herein
pursuant to Labor Code § 2699(a). To the extent that any violation
alleged herein does not carry a penalty, Mr. Sheen seeks civil
penalties pursuant to Labor Code § 2699(f) for Mr. Sheen's and other
current and former employees for violations of those sections.

75. Mr. Sheen is also entitled to an award of attorney fees and costs
pursuant to the applicable provisions of the Labor Code.


EIGHTH CAUSE OF ACTION

(By Plaintiff Charlie Sheen for Violation of FEHA Against Defendant
WB)

76. Plaintiffs incorporate herein by reference each and every
allegation contained in Paragraphs 1 through 33, inclusive, of this
Complaint as if fully set forth herein.

77. Defendant WB has accused Mr. Sheen of having physical and mental
disabilities. According to WB, health care experts have observed
Mr. Sheen in an alleged "manic" and/or "bi-polar" state; other
health-care experts have described Mr. Sheen as
suffering from "hypomaniac" psychological state. WB further claims
that Mr. Sheen has had a rapid physical and mental deterioration of
his condition. WB bluntly states that Mr. Sheen is very ill.

78. On or about March 7, 2011, WB refused to reasonably accommodate
Mr. Sheen from Warner Bros. claim that Mr. Sheen has an alleged
illness and need for medical care and/or treatment when it terminated
his employment contract. Rather than accommodate Mr. Sheen for Warner
Bros. claim that Mr. Sheen has alleged physical and mental
disabilities, WB instead terminated Mr. Sheen's employment agreement.

79. In mid-February 2011, Mr. Sheen advised WB that he was ready,
willing and able to perform his acting services such that production
of the Series could resume filming and production. However, WB, at the
urging of Lorre, arbitrarily refused to allow production to go forward
to the scheduled completion date, and instead arbitrarily insisted on
ending production two weeks early so that only four additional
episodes would be produced.  However, on or about February 28, 2011,
WB cancelled production of the remaining episodes of the current
season of the Series, and on or about March 7, 2011, terminated the
Acting Agreement. At no time was Mr. Sheen's performance of his acting
duties, with a reasonable accommodation for Warner Bros. claim of his
alleged physical and mental disabilities, a danger to either Mr. Sheen
or any other person's health or safety. Neither would an accommodation
of Mr. Sheen's medical needs based on Warner Bros. claim of
Mr. Sheen's alleged physical or mental disability have imposed an
undue hardship on WB.

80. WB stated that Mr. Sheen's termination of his employment agreement
was due to his alleged inability to perform the essential duties of
his position. The reasons given by WB are a pretext for discrimination
on account of Warner Bros. claim of Mr. Sheen's alleged physical and
mental disability.

81. WB's discriminatory actions against Mr. Sheen constitute unlawful
discrimination in employment on account of alleged physical and mental
disabilities in violation of Government Code § 12940(a). On March 9,
2011, Mr. Sheen filed a charge of discrimination with the California
Department of Fair Employment and Housing.

82. As a proximate result of WB's discriminatory actions against
Mr. Sheen, Mr.  Sheen has been banned in that he has suffered the loss
of wages and salary and benefits and additional amounts of money he
would have received had WB not terminated his employment agreement. As
a result of such discrimination and consequent harm, Mr. Sheen has
suffered damages in an amount to be proven at trial.

83. As a further direct and proximate result of WB's discriminatory
actions against Mr. Sheen, Mr. Sheen has been harmed in that he has
suffered intangible losses of such employment-related opportunities as
continuing to participate in television's top-rated sitcom and the
ancillary endorsements that flow from participating on a hit
television series. As a result of such discrimination and consequent
harm, Mr. Sheen has suffered damages in an amount to be proven at
trial.

84. WB's actions in terminating Mr. Sheen's employment agreement were
done with malice, fraud or oppression, and in a reckless disregard of
Mr. Sheen's rights under the FEHA. Specifically, WB terminated
Mr. Sheen in a public fashion, one designed to injure him as a result
of the physical and mental disabilities which Warner Bros. claims he
has. As a result of such discrimination and consequent harm, Mr. Sheen
is entitled to punitive and exemplary damages against WB in an amount
to be proven at trial.

85. As a further and direct proximate result of WB's conduct,
Plaintiff Sheen has been required to retain legal counsel, all of
which entitles him to an award of attorney's fees in a sum according
to proof.


NINTH CAUSE OF ACTION

(By Plaintiff Charlie Sheen for Retaliation In Violation of FEHA
against All Defendants)

86. Plaintiffs incorporate herein by reference each and every
allegation contained in Paragraphs 1 through 33, inclusive, of this
Complaint as if fully set forth herein.

87. Lorre, on his own behalf and on behalf of CLPI, engaged in an
ongoing campaign of harassment against Mr. Sheen and made numerous
derogatory and highly damaging statements about Mr. Sheen. On
information and belief, Lorre believed, and has stated publicly, that
Mr. Sheen suffered from physical and mental maladies, but Lorre
nevertheless repeatedly made offensive, derogatory and damaging
comments about Mr. Sheen and his alleged physical and mental illness,
and harassed Mr. Sheen on the set of the Series. With the permission
of WB, Mr. Lorre also spread outrageous insults and derogatory remarks
targeting Mr. Sheen in vanity cards at the end of Mr. Lorre's shows,
specifically targeting Mr. Sheen's alleged illness. Among the
harassing statements Mr. Lorre made in those vanity cards with an
obvious reference to Mr. Sheen are the following:

Under the heading "To Do List" Mr. Lorre wrote, "Meditate using new
mantra, 'high ratings do not equate to high self esteem'" "Go to
Al-Anon meeting" and "write a country song entitled, 'Hooker in the
Closet'."  "(Chorus: 'There's a hooker in the closet, 'neath the
monogrammed robes, don't know how she got there and I can't find my
clothes. Officer Krupke, how are you tonight? I've misplaced my watch
but I'm feeling all right.')"

Following statements about his own healthy lifestyle, Lorre wrote: "If
Charlie Sheen outlives me, I'm gonna be really pissed."

Lorre suggested that persons viewing this shall not drink to excess
and "avoid degrading yourself by having meaningless sex with strangers
in a futile attempt to fill the emptiness in your soul."

Lorre suggested that audience members extend prayers to people working
on the Series, and that viewers should "feel free to pick whomever
you think is most in need. Just hurry."

Lorre wrote, "We employ a highly paid Hollywood professional who has
years of experience with putting his life at risk. And sadly no, I'm
not talking about our stuntman."

88. In response to Lorre's unlawful practices under the FEHA by
harassing Mr. Sheen about his alleged disabilities, and his public
humiliation of Mr. Sheen and degrading comments about him and his
alleged disabilities, Mr. Sheen publicly protested the adverse
treatment and he tried to defend himself on or about February 24,
2011. Mr. Sheen pointedly protested Mr. Lorre's unrelenting unlawful
harassment. Mr. Sheen fought back against Lorre by using the same
court of public opinion that Lorre used. The fact that Mr. Sheen's
defense of himself was far more effective than Lorre's harassing and
degrading comments caused both Lorre and WB to take the ultimate
retaliatory action against Mr. Sheen. Indeed, WB admits that it was
Mr. Sheen's alleged condition and his statements about Lorre that
caused WB to cancel the production of the Series for the remainder of
the 2010-2011 season. In response to WB's and Lorre's retaliatory
actions against him by cancelling the remaining episodes for the
2010-2011 season of the Series, Mr. Sheen again publicly protested by
granting radio and television interviews to air his grievances with WB
and Lorre. Mr. Sheen publicly protested what he believed to be
discriminatory animus directed towards him.

89. On March 7, 2011, WB engaged in the ultimate retaliatory
action. It terminated Mr. Sheen's employment agreement. WB's actions
were caused by and were in retaliation for Mr. Sheen's protected
activity.

90. WB's discriminatory actions against Mr. Sheen constitute unlawful
discrimination of employment in violation of Government Code §
12940(h).

91. As a proximate result of WB's discriminatory actions against
Mr. Sheen, Mr. Sheen has been harmed in that he has suffered the loss
of wages and salary, and additional amounts of money Plaintiff would
have received had the Series continued. As a result of such
discrimination and consequent harm, Plaintiff has suffered damages in
an amount to be proven at trial.

92. As a further proximate result of Defendants' discriminatory
actions against Mr. Sheen, Mr. Sheen harmed in that he has suffered
the intangible loss of employment-related opportunities such as the
ability to continue in television's top-rated sitcom as well as the
attendant endorsements that come with being the lead character in that
type of television series.  As a result of such discrimination and
consequent harm, Mr. Sheen has suffered damages in an amount to be
proven at trial.

93. WB's actions in terminating Mr. Sheen in retaliation for
Mr. Sheen's opposition to WB's complicit agreement to permit Lorre to
engage in unlawful harassment against Mr. Sheen in violation of the
FEHA, was done with malice, fraud or oppression, and in reckless
disregard of Mr. Sheen's rights under the FEHA. Specifically, WB
understood that Mr. Sheen suffered from alleged physical and mental
disabilities, as it has publicly claimed, and it nevertheless
permitted Lorre to harass, harangue, degrade, and defame Mr. Sheen
both on the set of the Series as well as in the court of public
opinion, all to the detriment and injury of Mr. Sheen. For this
reason, Mr. Sheen should be entitled to an award of punitive and
exemplary damages against WB.

94. As a further and direct proximate result of WB's conduct,
Mr. Sheen has been required to retain legal counsel, all of which
entitles him to an award of attorney's fees in a sum according to
proof.


PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:

On the First Cause of Action:
1. For compensatory damages in the sum of One Hundred Million Dollars,
or according to proof at trial; and
2. For exemplary or punitive damages in an amount according to proof
at trial;

On the Second Cause of Action:
3. For compensatory damages in the sum of One Hundred Million Dollars,
or according to proof at trial; and
4. For exemplary or punitive damages in an amount according to proof
at trial;

On the Third Cause of Action:
5. For compensatory damages in the sum of One Hundred Million Dollars,
or according to proof at trial; and
6. For attorneys fees, costs and expenses incurred in enforcing an
award obtained under the Acting Agreement as provided by its terms;

On the Fourth Cause of Action:
7. For compensatory damages in the sum of One Hundred Million Dollars,
or according to proof at trial; and

On the Fifth Cause of Action:
8. For compensatory damages in an amount according to proof at trial;

On the Sixth Cause of Action:
9. For compensatory damages in an amount to be proven at trial,
representing wages and other compensation owed to Plaintiffs;
10. For interest on the amount of unpaid wages and other compensation
owed to Plaintiffs;
11. For penalties in an amount to be proven at trial pursuant to the
applicable provisions of the Labor Code; and
12. For reasonable attorneys' fees pursuant to the applicable
provisions of the Labor Code;

On the Seventh Cause of Action:
13. For compensatory damages in an amount to be proven at trial,
representing wages and other compensation owed to Plaintiffs and other
similarly situated current and former employees of Warner Bros.;
14. For interest on the amount of unpaid wages and other compensation
owed to Plaintiffs and other similarly situated current and former
employees of Warner Bros.;
15. For penalties in an amount to be proven at trial pursuant to the
applicable provisions of the Labor Code; and
16. For reasonable attorneys' fees pursuant to the applicable
provisions of the Labor Code;

On the Eighth Cause of Action:
17. For compensatory damages in an amount according to proof at trial;
18. For exemplary or punitive damages in an amount according to proof
at trial; and
19. For attorneys fees and other amounts recoverable under FEHA;

On the Ninth Cause of Action:
20. For compensatory damages in an amount according to proof at trial;
and
21. For exemplary or punitive damages in an amount according to proof
at trial; and
22. For attorneys fees and other amounts recoverable under FEHA;

On All Causes of Action:
23. For costs of suit incurred herein;
24. For attorneys fees as allowable by law; and
25. For such other and further relief as the Court may deem just and
proper.


DATED: March 10, 2011

LAVELY & SINGER
PROFESSIONAL CORPORATION
MARTIN D. SINGER
PAUL N. SORRELL
WILLIAM J. BRIGGS II

By: MARTIN D. SINGER
Attourneys for Plaintiffs CHARLIE SHEEN
and 9th STEP PRODUCTIONS, INC.


DEMAND FOR JURY TRIAL

Plaintiffs Charlie Sheen and 9th Step Productions, Inc., hereby demand
a trial by jury in this matter.

DATED: March 10, 2011

LAVELY & SINGER
PROFESSIONAL CORPORATION
MARTIN D. SINGER
PAUL N. SORRELL
WILLIAM J. BRIGGS II

By: MARTIN D. SINGER
Attourneys for Plaintiffs CHARLIE SHEEN
and 9th STEP PRODUCTIONS, INC.