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Page 1 Electronically FILEDby Superior Court of California, County of Los Angeles on 12/11/2020 08:30 AM Sherri R. Carter, Executive Officer/ Clerk of Court, by R. Clifton Deputy Clerk
20STCV47437
:
Assigned for all purposesto SpringStreet Courthouse JudicialOfficer: Kristin Escalante
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BRYANJ. FREEDMAN( SBN 151990)
bfreedman@ftllp.com
SEAN M.
HARDY(SBN 266446)
smhardy@ftllp.com
FREEDMAN + TAITELMAN, LLP
1801CenturyParkWest, 5th Floor
LosAngeles, California90067
Tel.: ( 310) 201-0005
Fax : ( 310) 201-0045
Attorneys for Plaintiff Tahliah Barnett
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SUPERIORCOURTOF THE STATEOF CALIFORNIA
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COUNTYOF LOSANGELES
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TAHLIAHBARNETT, an individual,
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Case No.:
Plaintiff
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COMPLAINTFOR:
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1.
SHIA LABEOUF , an individual ,
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Defendant
.
2.
3.
4.
SEXUAL BATTERY;
BATTERY;
ASSAULT ;
INTENTIONAL INFLICTION OF
EMOTIONALDISTRESS; AND
5.
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GROSSNEGLIGENCE
DEMAND FOR JURY TRIAL
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Plaintiff TAHLIAH BARNETT (hereinafter sometimes referred to as “ Plaintiff
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“ Tahliah”) hereby brings the following causes of action against Defendant SHIA LABEOUF
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(“ LaBeouf” or “Defendant with knowledge as to herself and otherwise on information and belief,
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claim and allege as follows:
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COMPLAINTPage 2 1
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INTRODUCTION
1.
Shia LaBeoufhurts women. He uses them. He abuses them, both physically and
mentally. He is dangerous. For too long, LaBeoufhas sought to excuse his reprehensible actions as
the eccentricities of a free-thinking “ artist.” Even though his history of violent behavior was well
documented, many in the media have treated LaBeoufas a harmless figure of fun,which has helped
enable him to perpetuate his cycle ofabuse of women over the years. There is nothing funny about
the exploitation of and battering of women. This action has been brought not for personal gain, but
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to set the recordstraight, and to help ensure that no more women must undergothe abuse that Shia
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LaBeoufhas inflicted on his prior romantic partners. The days in which LaBeoufcan mistreat and
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harmwomen with impunityare over.
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.
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Tahliah Barnett, professionally known as FKA twigs, is an internationally successful
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singer, songwriter, and actor. Tahliah was involved in a tumultuous relationship with LaBeouf
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shortly after they finished working on the motionpicture Honey
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a
charm offensive”
. After LaBeoufhad employed
on Tahliah , a tactic she now knows he used on other women, LaBeouf
convinced her to move in with him. LaBeouf was engaging in grooming
gradually gaining
Tahliah’s trust and confidence with the intent of abusingher. What followed was a livingnightmare
for Tahliah . Over a course of months, LaBeouf engaged in a continuous stream of verbal and
mental abuse toward Tahliah, belittling her and berating her after the slightest perceived “insult
LaBeouf. LaBeouf isolated Tahliah from her friends and family, making it so her daily existence
and routine revolved around LaBeouf and only LaBeouf. His verbal abuse escalated into physical
abuse, during which LaBeouf became increasingly violent toward Tahliah. On one horrific
occasion, around Valentine's Day 2019 , LaBeouf forcibly slammed Tahliah against his car and then
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strangled her after she was trying to escape from one of his manic tirades . In fact, LaBeouf even
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admitted to another woman, whom he was cheating on Tahliah with at the time, that he had dragged
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Tahliah out of his car by her collar. LaBeouf kept Tahliah in a constant state of fear by openly
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storing live firearms throughout his home, including in the bedroom he shared with Tahliah.
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Finally, and most dreadfully, LaBeouf knowingly transmitted a serious illness to Tahliah , without
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ever informing her beforehand that he suffered from this dreadful malady . Tahliah has since learned
COMPLAINTPage 3 1
that LaBeouf has infected other unsuspecting women with his disease . Simply put LaBeouf's
reckless disregard for the health and safety of his partners makes him a danger to women
3 | everywhere.
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3.
Although Tahliah has suffered greatly , and will bear the scars of LaBeouf's abuse for
the rest of her days , she will not be labeled a victim. Instead, Tahliah has triumphed over LaBeouf's
abuse and stands ready to hold him accountable for his actions . Together with Karolyn Pho, another
survivor of LaBeouf's abuse, Tahliah sought to avoid this action by requesting LaBeouf voluntarily
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seek the mental health and substance abuse treatment he so desperately needs, and that he make a
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donation to a domestic violence shelter. Tahliah and Karolyn simply wanted LaBeouf to take
affirmative steps toward healing himself and, in turn, to stop his cycle of domestic violence toward
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his future partners and keep them from suffering the same physical, sexual, and mental abuse.
4.
In response to this peaceful overture, LaBeouf played games and downplayed the
seriousness of the situation. LaBeouf's attorney cruelly dismissed the sexually transmitted disease
14 LaBeoufhad infected Tahliah with as “not that bad.” LaBeoufattempted to dissuade Karolyn from
15 | allying with Tahliah by sending Karolyn an unsolicited email in which he falsely disparaged
16 Tahliah. LaBeouf also threatened Tahliah, claiming that he was in possession of personal text
messages and other information that he could use to embarrass her. In his effort to intimidate
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Tahliah, LaBeouf engaged
former assistant Noelle O'Reilly into improperly providing
him with private and confidential information about Tahliah. With these threats, LaBeouf clearly
hoped to terrorize Tahliah into submission and keep her from taking any further action LaBeouf's
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scare tactics will not work . He has no power over Tahliah anymore .
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.
Tahliah now brings this action to seek some measure ofjustice not simply for herself
but for the many other women who have been similarly abused by LaBeouf. Tahliah intends to
donate a significant portion of any monies received in this action to charities dedicated to assisting
victims of domestic violence. Never again will another woman be forced to undergo the brutal
treatment and degradation that Tahliah and others experienced at his hands. This case is being
brought on behalf of all those women that LaBeouf has mistreated in the past, and for all those
women who will be spared his abuse in the future.
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COMPLAINTPage 4 1
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PARTIES AND JURISDICTION
6.
Plaintiff Tahliah Barnett is, and at all times relevant was, an individual residing in
London, England, United Kingdom .
7.
Defendant LaBeouf is, and at all times relevant was, an individual residing in the
County ofLos Angeles, State ofCalifornia.
8.
The wrongfulacts by LaBeoufalleged herein occurredinthe County ofLos Angeles,
State of California .
FACTS COMMON TO ALL CAUSES OF ACTION
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LaBeouf's Abuse of Tahliah
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Tahliah first met LaBeoufwhile filming the motion picture “ Honey Boy” in the early
summer of 2018, a film in which both had lead roles. When shooting on the picture wrapped later
that year, the two began a romantic relationship. Tahliah was in a vulnerable and sensitive state at
the time, as she had recently ended a four-year engagement and was recovering from having painful
fibroidtumors removedfrom her uterus
.
10.
Within a week or two of dating, LaBeouf dramatically professed his love for Tahliah .
During the first few months of their relationship , LaBeouf restrained himself to over-the-top
displays of affection, eventually winning Tahliah's trust Once LaBeouf had gained Tahliah's
confidence , her living nightmare began.
11.
Beginning in and around October 2018, LaBeouf convinced Tahliah to go live with
him at his Los Angeles home. Once Tahliah had moved in, LaBeouf began regularly exhibiting
frequent rage and bouts of jealousy toward Tahliah. On a continual basis, he aggressively accused
her of dwelling on her former fiancé (well-known actor Robert Pattinson and also accused Tahliah
of “ rushing” him into a relationship. LaBeouf would inexplicably escalate the most inconsequential
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disagreements — for example, over matters of taste in artapocalyptic levels, often forcing
Tahliah to stay up all night while he verbally berated her for hours on end about her supposed lack
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oftaste. LaBeoufwould take something as innocent as Tahliah kissing another man on the cheek in
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COMPLAINTPage 5 1
a music video, or being polite to a waiter, as nothing less than a betrayal, an assault on his manhood,
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and an existential threat to their relationship.
12.
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LaBeouf would literally count the kisses Tahliah would give him in a given day and
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berate her if she fell short of a target number. He would verbally assault Tahliah if he placed his
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hand in her lap and she failed to immediately reciprocate and place her hand on top of his. He
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would “ end ” their relationship on the slightest imagined grievance and then almost immediately
resurface, desperate to resume it.
13.
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LaBeouf suffered recurring periods of delusions wherein he armed himself with
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firearms on the belief “ gang members ” were going to break down his door at any moment , going so
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far as to sleep with these guns . Tahliah would be trapped in their shared bed for hours at a time
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without the ability to even get up to go to the bathroom for fear she would be shot by LaBeouf
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should he wake up suddenly upon her return to bed.
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.
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LaBeouf's relentless mental and verbal harassment and mistreatment of Tahliah
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eventually turned into physical violence . LaBeouf committed physical attacks against Tahliah on
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multiple occasions, each resulting in personal injuries to Tahliah, not the least of which was
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LaBeouf's knowing transmission of a serious disease which has forever altered the course of her
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life.
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15.
While Tahliah was living with LaBeouf at his Los Angeles home, she remained in
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constant fear due to the threatening presence of loaded firearms throughout LaBeouf's home.
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Beginning in November 2018, LaBeouf insisted on keeping his front door unlocked and sleeping
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with a loaded rifle at their bedside. LaBeouf demanded Tahliah join him while he watched
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documentaries about murdered women before bed and refused to allow Tahliah to sleep with any
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clothing on. In these moments, Tahliah would often text friends inthe middle of the night to devise
a plan to escape LaBeouf's home.
16.
Similarly, when LaBeouf was filming the movie The Tax Collector, in which he
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played a gangster, he took on the role in real life. During one incident, while Tahliah was driving
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with him LaBeoufpulled a pistol from a compartment in his car which he boasted to Tahliah was
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illegal to possess in California. On another occasion, LaBeouf attempted to scare Tahliah by
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COMPLAINTPage 6 1
warning her that he pulled out one of his firearms on set and threatened others with it, bragging to
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Tahliah that he enjoyed “ getting their attention.” LaBeoufmade the horrific boast to Tahliah that, in
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order to get into “ character” for his role in The Tax Collector, he would drive around neighborhoods
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in Los Angeles and shoot stray dogs. LaBeouf claimed he killed these dogs because he wanted to
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know what it felt like to take a life so he could get into the “ mindset” of a killer, like his role in the
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movie . LaBeouf knew that Tahliah is a great lover of dogs, and that she is very close to her own
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dog.
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Tahliah
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LaBeouf's admission to such wanton animal cruelty profoundly disturbed and terrified
17.
To celebrate the Valentine's Day holiday in February 2019, LaBeouf drove Tahliah
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to a hotel spa for a romantic evening. However, instead of a night of romance , Tahliah was
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subjected to a torrent of physical abuse from LaBeouf. After she had gone to bed, Tahliah awoke to
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LaBeouf towering over her and violently squeezing her body and arms against her will. LaBeouf
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then grasped his hands around Tahliah's neck and began strangling her while whispering, “If you
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don't stop you are going to lose me.” Tahliah was so terrified she could not move and lay there
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frozenwhile LaBeoufcontinuedto harmher.
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18 .
The following morning, outside of their hotel, LaBeouf threw Tahliah to the ground .
And as they drove back to LaBeouf's house, LaBeouf drove maniacally , removing his seat belt and
threatening to crash the car unless Tahliah professed her eternal love for him. Tahliah was horrified
by LaBeouf's actions and feared for her life. LaBeouf eventually stopped at a gas station, and
Tahliah desperately attempted to escape from him. However, after Tahliah tried to remove herself
and her belongings from the car, LaBeouf violently attacked Tahliah . While in the gas station
parking lot, he threw Tahliah against the car and attempted to strangle her violently while screaming
in her face. LaBeoufthen forced Tahliah back into his car.
19.
Later, when confronted about this incident by his female friend on September 29,
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2019 LaBeouf did not deny that he used violence on Tahliah .
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message that, “ I do remember removing her [ Tahliah from the car in the desert.” LaBeouf stated
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that he removed Tahliah “ b ]y her arms.” In response, LaBeouf's friend confronted him with a text
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message stating, “ Shia, you did actually admit to me the incident when you had her [ Tahliah]
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COMPLAINT
Indeed, LaBeouf admitted it a text
thePage 7 1
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collar and were pushingher against the car while she sobbed, and while three male witnesses did
nothingat the gas station was true[. ]”
20.
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Shortly after the Valentine's Day incident, on February 25, 2019 Tahliah reached
out for help, by texting a close friend and writing, “...
is difficult to say but I am sure you
know. I have been in an abusive relationship that has isolated me. It's worse than you could
imagine.
21.
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Tahliah also sought the help of a professional therapist, writing to him on February
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24, “ I have just left an emotionally , physically, and sexually abusive relationship. I have one day
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out and
very confused and overwhelmed .... am writing this emailbecause I am hoping that
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by seeking professional help I can stay out of it and carry on with my life.” Tahliah has continued
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to seek counseling and psychotherapy from this therapist, as she continues to suffer ongoing mental
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trauma and distress from LaBeouf's relentless abuse.
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22 .
Tahliah began to slowly distance herself from LaBeouf and his violence . She began
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this process by planning to escape from LaBeouf when the opportunity arose. However, LaBeouf's
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fixation on controlling and surveilling Tahliah made the prospect of escape both difficult and
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dangerous
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23 .
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In and around March 2019, Tahliah attempted to escape from LaBeouf's abuse. One
day she began packing her bags and belongings , intending to leave Los Angeles and LaBeouf.
However , while Tahliah was doing so , LaBeouf showed up unannounced at the rented home where
she was staying . The entire incident was witnessed by Tahliah's housekeeper , who was helping her
at the time. In her own words , the housekeeper had provided sworn testimony that,
“ LaBeouf yelled at [Tahliah ] that she had to come with him. [ Tahliah ] hesitated and remained
where she was in the room . When [ Tahliah ] refused to go with [LaBeouf ], [LaBeouf appeared to
grow angrier and moved toward [Tahliah ] [LaBeouf then violently grabbed [ Tahliah ] and lifted
her off the ground .”
24 .
Tahliah’s housekeeper further relates that “[ a]fter [LaBeouf had lifted [Tahliah]
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into the air, he forcibly carried her into a separate room. I then heard the door to this room lock
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from the inside. I tried the door and confirmed that it was locked. [LaBeouf continued to scream
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COMPLAINTPage 8 1
at [Tahliah . He yelled so loudly that I could hear him from outside the room. I waited outside the
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room while this occurred . [LaBeouf kept yelling at [Tahliah] for a considerable amount of time .
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Eventually, I observed [LaBeouf] open the door and exit the room where he had been keeping
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[ Tahliah
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stared at me but did not say anything. "
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.
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As he left the room, [ LaBeouf first appeared to notice me watching him.
[ LaBeouf]
Finally, Tahliah’s housekeeper has testified that, “ I quickly went to [ Tahliah ] side
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to see how she was doing . I observed that [Tahliah] was in a very traumatized state. She appeared
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to have been crying and her voice was very weak . I asked [Tahliah ] if [LaBeouf had taken her into
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that room and kept her there against her will . [Tahliah confirmed that [ LaBeouf had indeed done
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so .” Unfortunately , LaBeouf soon returned, dashing Tahliah’s plans to escape from him.
in and around March 2019 Tahliah began to experience unusual and
painful physical symptoms. Shortly thereafter , Tahliah confronted LaBeouf about her symptoms
and he admitted that he suffered from a sexually transmitted disease which had been diagnosed
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Beginning
14
years earlier . LaBeouf admitted that he had never told Tahliah about his condition before, even
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though they had been sexually intimate for many months. Further, LaBeouf admitted that he had
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experienced a flareup of his disease's symptoms in December 2019, but worked to hide his outward
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symptoms from Tahliah by applying makeup. Despite experiencing a flareup of his symptoms,
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LaBeouf continued to engage in sexual relations with Tahliah , further exposing her to his disease .
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27 .
Shocked and horrified by this revelation, Tahliah consulted with her physician who
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performed blood work and confirmed that Tahliah had been infected with LaBeouf's disease .
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Tragically, Tahliah later learned that she was not the first person that LaBeouf had transmitted his
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disease to
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Tahliah discovered that at least one other woman that LaBeouf had been in a
relationship with had contracted the disease from him, and that he had engaged in similar attempts
to hide his condition from that person while engaging in sexual relations.
28 .
Despite his endless mistreatment of Tahliah , LaBeouf had succeeded in isolating her
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from her friends, family and others that could help extricate her from the toxic relationship.
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LaBeouf's domineering treatment of Tahliah had allowed him to convince her that he was a victim,
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that he genuinely loved her and that he wanted to “ repair” their relationship. For the next few
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COMPLAINTPage 9 months Tahliah engaged in multiple therapy sessions with LaBeouf, in an attempt to salvage their
2
3
relationship. However, LaBeouf's unpredictable and violent behavior did not change. Eventually,
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his relationship with Tahliah via a text message. Tahliah later learned that LaBeouf had been
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cheating with another woman during this time. Finally free from LaBeouf, Tahliah began the long
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and difficult process of healing from his abuse .
after Tahliahrefused his endless streamofcalls and text messages, LaBeoufunceremoniously ended
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LaBeouf's Prior History of Abuse
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29.
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As part of her path toward healing, Tahliah came into contact with Karolyn Pho
(“Karolyn” ), another survivor of LaBeouf's abuse. Karolyn dated LaBeouf during the years 2010 to
2011. Theirs was a well -documented and public relationship .
30 .
Behind that publicity , however LaBeouf subjected Karolyn to the same kind of
abuse, including physical abuse, he inflicted on Tahliah, fueled by his jealous, impulsive , and
irrational ways. For example, just as LaBeouf was fixated on Tahliah's former fiancé and would
accuse her, constantly , of still being emotionally drawn to him, LaBeouf would berate Karolyn for
something as innocuous as “ looking ” at the male waiting staff at a restaurant. LaBeouf would
furiously claim that Karolyn was attracted to any male, other than himself, that she happened to be
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looking” at instigating needless traumatic arguments with Karolyn.
31 . Karolyn's experience with LaBeouf was disturbingly similar to Tahliah’s
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demonstrating his pattern and practice of abusing women . For instance , in February 2012, LaBeouf
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traveled with Karolyn to New York City for Fashion Week . During their flight east, paid for by
21 Karolyn , LaBeouf angrily berated her for wearing expensive sunglasses and repeatedly humiliated
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her, causing her to burst into tears in front of other passengers on the airplane. He disappeared the
moment he deplaned at JFK airport. Karolyn traveled to their hotel alone, could not find LaBeouf,
and went to bed . LaBeouf eventually showed up to the hotel room extremely drunk, waking
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Karolyn by banging loudly on the door . Karolyn let LaBeouf into their room, where , after babbling
26 | incoherently , he promptly passed out on the couch face up . Fearful that LaBeoufmightchoke on his
own vomit in that position , Karolyn helped carry him into a shower , where she sat him upright and
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turned on the water . LaBeouf continued to sit in this position , mumbling to himself. Believing
COMPLAINTPage 10 1
LaBeouf was no longer in danger Karolyn returned to bed.
2
LaBeouf on top of her
3
intense pain and leaving multiple bruises, and then headbutted her violently causing her to bleed on
4
the hotel bed.
32 .
5
Later that night, Karolyn awoke to
drunk , naked , wet, and screaming . He held her down by her arms, causing
Likewise, following a party at the Chateau Marmont in early 2011, Karolyn kept
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LaBeouf from driving home because of how drunk he was . They hailed a taxi. On the ride home to
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Sherman Oaks, LaBeouf repeatedly berated and verbally assaulted Karolyn in front of the driver,
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and repeatedly whispered to Karolyn, “ You know I'mgoing to kill you.” Once home , he vomited in
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the hallway . The next morning, LaBeouf asked Karolyn about the vomit in the hallway , claiming he
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had " blacked out " and did not remember anything from the prior evening.
33 .
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Karolynhas bravely chosen to ally with Tahliah against LaBeouf, in order to protect
women from ever again having to endure LaBeouf's abuse.
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LaBeouf's Documented History of Arrests and Violence
14
34 .
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Over the years, the media has reported on public examples of LaBeouf's violent and
volatile behavior. In 2007, for instance, LaBeouf was arrested and jailed following an altercation
with his next-door neighbor in Van Nuys, California. In 2008, LaBeoufnarrowly avoided seriously
17
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injuring others when his drunk driving caused him to hit another vehicle, resulting in his arrest. In
19
detained by police.
2011, LaBeoufwas involved in a bar fight in Sherman Oaks, California, which resulted in his being
In 2014, LaBeouf attended a performance of the musical Cabaret on
20 Broadway. LaBeouf was extremely drunk during the performance, and caused such a disturbance
that he was arrested during the show's intermission . In 2015, LaBeouf's drunk and disorderly
22
behavior resulted his arrest on the streets of Austin , Texas.
23
24
1
See https://people.com/crime/shia-labeouf-arrested-for-dui/
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2
See https://www.hollywoodreporter.com/news/shia-labeouf-handcuffed-released-bar-96959
26
27
28
3 See https://pagesix.com/2014/06/26/shia-labeouf-arrested-for-disorderly-conduct/
See https://www.usatoday.com/story/life/people/2015/10/09/shia-labeouf-arrested-public
intoxication -in -texas /73694686 /
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COMPLAINTPage 11 1
35.
In 2015, the media widely reported on an incident between LaBeouf and his then-
2
girlfriend
3
captured on video by passersby. Among other things, LaBeouf told Goth, “I don’t wanna touch
Mia Goth (“Goth”). While in Germany, LaBeouf’s vicious verbal assault on Goth was
you. I don’t wanna be aggressive. This is the kind of shit that makes a person abusive.” LaBeouf,
apparently inebriated, blames Goth for “pushing” him. When he eventually leaves the scene,
6 LaBeouf was caught saying, “If I’d have stayed there, I would have killed her.”5
7
36.
As recently as September 24, 2020, LaBeouf was charged by the Los Angeles City
8 Attorney with misdemeanor battery and theft for allegedly using physical violence to steal a man’s
hat.6
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LaBeouf’s Enlists Tahliah’s Former Assistant to Threaten Her
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37.
From 2017 until 2019, Tahliah employed Noelle O’Reilly (“O’Reilly”) as her
personal assistant. Inconnection with her employment with Tahliah, O’Reilly was privy to certain
private and confidential information concerning Tahliah’s personal life and career that O’Reilly was
obligated not to disclose. However, it has since become clear to Tahliah that O’Reilly repeatedly
abused her position of trust by engaging in fraud and outright theft. Moreover, O’Reilly undertook
most of her misdeeds while Tahliah was away from her home, living with LaBeouf.
17
38. In August through October 2018, after her own application was denied, and desperate
to become a member of the exclusive Soho House chain of clubs, O’Reilly committed identity theft
and hacking in order to pose as Tahliah so she could “recommend” herself for a club membership.
20 Once O’Reilly was approved, she then stole from Tahliah by paying for her Soho House
membership with Tahliah’s money. All of this was done without Tahliah’s knowledge and consent.
22
23
24
25
5
See https://www.huffpost.com/entry/shia-labeouf-mia-goth-public-fight-
germany_n_55b64e86e4b0224d8832c8e1
26
27
6
See
https://www.nbcnews.com/news/us-news/actor-shia-labeouf-charged-misdemeanor-battery-
petty-theft-n1241857
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COMPLAINTPage 12 1
39.
As if posing as Tahliah in order to gain a club membership was not enough,
stole articles of
designer clothing
website Vestiaire Collective.
from Tahliah and sold them for her own
O’Reilly
then directed that the
profit
O’Reilly
via the resale
from these illicit sales be
proceeds
directed to her personal account with Vestiaire Collective. For instance, on October 4, 2018,
5 O’Reilly emailed Vestiaire stating, “I have a large collection of designer items, 100-150. I can’t list
them all . . . . Account is under this email address.” This collection of
7 Tahliah’s
personal property.
This led to a
viewing appointment
between
“designer
O’Reilly
items” was
and Vestiaire
representatives on November 14, 2018, at Tahliah’s house – without Tahliah’s consent and while
she was away. The following day, when Vestiaire informed O’Reilly that 15 of the items would
need to be returned,
11
40.
O’Reilly
had them returned to her own residence – not Tahliah’s.
Unaware of her
duplicity,
Tahliah confided in
O’Reilly
about LaBeouf’s violent
abuse of her. Indeed, O’Reilly took photographs of the bruises that LaBeouf inflicted on Tahliah in
13 February 2019. O’Reilly even sent a text message to Tahliah’s friends to warn them that Tahliah
was in an abusive
theft, she
began
relationship. However,
soon after Tahliah uncovered
to aid LaBeouf in his intimidation
campaign against
O’Reilly’s deception
and
Tahliah. After Tahliah and
16 Karolyn approached LaBeouf about informally resolving this dispute, which would have involved
17 LaBeouf undergoing intensive psychotherapy and substance abuse treatment in addition to donating
to a domestic violence shelter, LaBeouf began an intimidation campaign
her from
filing
this lawsuit. LaBeouf stated that
O’Reilly
had
against
provided
Tahliah to
frighten
him with sensitive and
confidential information, obtained during O’Reilly’s employment with Tahliah, which he would use
to embarrass Tahliah if she ever went public about LaBeouf’s abuse. He also claimed that O’Reilly
had provided a statement in which she would claim that Tahliah’s
result from LaBeouf’s
physical violence,
February
2019 bruises did not
but were self-inflicted from a strenuous
dancing
session
24 Tahliah had that month. By providing confidential information and false statements to LaBeouf,
whom she knew had abused Tahliah, O’Reilly not only violated Tahliah’s trust and confidence but
also her own contractual
27
recording
obligations
artist in the music
informed Tahliah that
industry
O’Reilly
also
to Tahliah. Tahliah has since
who had also
engaged
employed O’Reilly
spoken
with a
high-profile
as his assistant. That artist
in the theft of his property while under his employ.
12
COMPLAINTPage 13 1 The fact that LaBeouf would enlist such a
2
3
speaks volumes
41.
disreputable
person to support his intimidation tactics
about his own character, or lack thereof.
Undeterred by LaBeouf’s shameful threats, and determined to keep any more women
from being ensnared and abused by such a dangerous man, Tahliah has pressed forward with this
action. If LaBeouf will not help himself and address his own demons, Tahliah will do everything in
her power to
keep
him from
hurting
action. She intends to donate a
8
9
others. Tahliah has nothing to
significant portion
gain professionally
from this
of any monies she receives from LaBeouf to
aimed at helping survivors of domestic abuse. Most importantly, women
are now on notice that LaBeouf is not the tortured artist he portrays himself as: he is a
deserving non-profits
everywhere
destructive and dangerous man.
FIRST CAUSE OF ACTION FOR SEXUAL BATTERY
11
12
13
42.
14
paragraphs
15
43.
(BY
PLAINTIFF AGAINST
LABEOUF)
herein by this reference each and every allegation contained in
through 41, inclusive, of this Complaint as if set forth fully herein.
done without
17
44.
18
45.
19
46.
Plaintiff
re-alleges
LaBeouf’s conduct in
transmitting
a
sexually
transmitted disease to Plaintiff was
Plaintiff’s consent and constitutes sexual battery.
LaBeouf intended to cause and did cause a harmful contact with Plaintiff’s person.
Plaintiff did not consent to LaBeouf’s harmful contact with her person.
As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
suffered bodily injuries, severe emotional and mental distress and anguish.
21
47. As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
suffered damages, all in amounts according to proof and in excess of the minimum jurisdiction of
this Court.
24
25
48.
LaBeouf
performed
the
intentionally, fraudulently, maliciously,
foregoing
and
wrongful
oppressively
acts, conduct, and omissions
in willful and conscious disregard of
Plaintiff. By reason thereof, Plaintiff is
26 Plaintiff’s rights and with the intent and design to damage
entitled to recover punitive damages in an amount to be determined at the time of trial.
28
13
COMPLAINTPage 14 SECOND CAUSE OF ACTION FOR BATTERY
1
2
(BY
3
49.
4
5
paragraphs
Plaintiff
re-alleges
PLAINTIFF AGAINST
herein
by
LABEOUF)
this reference each and every
allegation
contained in
through 48, inclusive, of this Complaint as if set forth fully herein.
6
50.
51.
LaBeouf intended to cause and did cause a harmful contact with Plaintiff’s person.
Plaintiff did not consent to LaBeouf’s harmful contact with her person.
7
52.
As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
suffered bodily injuries, severe emotional and mental distress and anguish.
9
53. As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
suffered damages, all in amounts according to proof and in excess of the minimum jurisdiction of
this Court.
12
13
54.
LaBeouf
performed
the
intentionally, fraudulently, maliciously,
foregoing
and
wrongful
oppressively
acts, conduct, and omissions
in willful and conscious disregard of
Plaintiff. By reason thereof, Plaintiff is
14 Plaintiff’s rights and with the intent and design to damage
entitled to recover punitive damages in an amount to be determined at the time of trial.
16
THIRD CAUSE OF ACTION FOR ASSAULT
17
(BY PLAINTIFF AGAINST LABEOUF)
18
55.
19
paragraphs
20
56.
21 Plaintiff.
22
57.
23
58.
Plaintiff
re-alleges
herein
by
this reference each and every
allegation
contained in
through 54, inclusive, of this Complaint as if set forth fully herein.
LaBeouf acted in a manner such that he intended to cause a harmful
touching
LaBeouf touched and assaulted Plaintiff in a harmful manner.
Plaintiff did not consent to the assaultive conduct committed
by
LaBeouf.
24
59. As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
suffered bodily injuries, severe emotional and mental distress and anguish.
26
60. As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
suffered damages, all in amounts according to proof and in excess of the minimum jurisdiction of
this Court.
14
COMPLAINT
ofPage 15 1
2
61.
LaBeouf
performed
the
intentionally, fraudulently, maliciously,
3 Plaintiff’s
rights
foregoing
and
wrongful
oppressively
and with the intent and design to
damage
acts, conduct, and omissions
in willful and conscious
Plaintiff.
By
disregard
of
reason thereof, Plaintiff is
entitled to recover punitive damages in an amount to be determined at the time of trial.
5
FOURTH CAUSE OF ACTION FOR INTENTIONAL INFLICTION OF
6
EMOTIONAL DISTRESS
7
(BY
8
9
62.
paragraphs
10
63.
PLAINTIFF AGAINST
LABEOUF)
and incorporate herein by reference the allegations contained in
through 61, inclusive, with the same force and effect as though fully set forth herein.
Plaintiff
reallege
The conduct of LaBeouf as
and carried out
by
alleged
above was at all times extreme and outrageous,
LaBeouf with an intention to cause Plaintiff emotional distress and/or with
reckless disregard of the probability of causing emotional distress to Plaintiff.
13
64. As a result of the conduct of LaBeouf, as alleged herein, Plaintiff has suffered severe
emotional distress and suffering.
15
65.
As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
suffered damages, all in amounts according to proof and in excess of the minimum jurisdiction of
this Court.
18
19
66.
LaBeouf
performed
the
intentionally, fraudulently, maliciously,
foregoing
and
wrongful
oppressively
acts, conduct, and omissions
in willful and conscious
disregard
of
20 Plaintiff’s rights and with the intent and design to damage Plaintiff. By reason thereof, Plaintiff is
entitled to recover punitive damages in an amount to be determined at the time of trial.
22
FIFTH CAUSE OF ACTION FOR GROSS NEGLIGENCE
23
(BY
LABEOUF)
24
25
paragraphs
26
68.
At all times relevant herein, LaBeouf owed Plaintiff a duty to act with ordinary care.
27
69.
LaBeouf breached his duties to Plaintiff
28
67.
PLAINTIFF AGAINST
diligence
and incorporate herein by reference the allegations contained in
through 41, inclusive, with the same force and effect as though fully set forth herein.
Plaintiff
reallege
in his actions toward Plaintiff.
15
COMPLAINT
by failing
to exercise
ordinary
care and duePage 16 70 .
1
2
LaBeouf's conduct constituted a want of even scant care and an extreme departure
from the ordinary standard of conduct.
71.
3
As a direct and proximate result of LaBeouf's grossly negligent conduct, Plaintiff
4
has suffered damages, all in amounts accordingto proof and inexcess of the minimumjurisdiction
5
of this Court
72.
6
As alleged herein, LaBeouf is guilty of oppression, fraud, and/or malice as defined in
7
Civil Code Section 3294. By reason thereof, Plaintiff is entitled to recover punitive damages in an
8
amount to be determined at the time of trial.
9
10
1.
For compensatorydamages accordingto proof;
11
.
WHEREFORE, Plaintiffprays for judgment against LaBeoufas set forth below:
2
For exemplary and/ or punitive damages as permitted by law;
12
3 .
For cost of suit herein
13
4 .
For such other and further reliefas the court may deemjust and proper;
14
5.
For a trial byjury on all causes ofactionas permittedby law.
15
FREEDMAN+ TAITELMAN, LLP
17
18
19
Dated
December 10, 2020
20
Bryan J. Freedman, Esq.
Sean M. Hardy, Esq.
21
Attorneys forPlaintiffTahliah Barnett
23
24
25
26
27
28
16
COMPLAINT
PDF Page 1
PlainSite Cover Page
PDF Page 2
Electronically FILEDby Superior Court of California, County of Los Angeles on 12/11/2020 08:30 AM Sherri R. Carter, Executive Officer/ Clerk of Court, by R. Clifton Deputy Clerk
20STCV47437
:
Assigned for all purposesto SpringStreet Courthouse JudicialOfficer: Kristin Escalante
1
2
3
4
5
6
BRYANJ. FREEDMAN( SBN 151990)
bfreedman@ftllp.com
SEAN M.
HARDY(SBN 266446)
smhardy@ftllp.com
FREEDMAN + TAITELMAN, LLP
1801CenturyParkWest, 5th Floor
LosAngeles, California90067
Tel.: ( 310) 201-0005
Fax : ( 310) 201-0045
Attorneys for Plaintiff Tahliah Barnett
7
8
SUPERIORCOURTOF THE STATEOF CALIFORNIA
9
COUNTYOF LOSANGELES
10
11
12
TAHLIAHBARNETT, an individual,
13
Case No.:
Plaintiff
14
COMPLAINTFOR:
15
1.
SHIA LABEOUF , an individual ,
17
Defendant
.
2.
3.
4.
SEXUAL BATTERY;
BATTERY;
ASSAULT ;
INTENTIONAL INFLICTION OF
EMOTIONALDISTRESS; AND
5.
18
GROSSNEGLIGENCE
DEMAND FOR JURY TRIAL
19
20
21
Plaintiff TAHLIAH BARNETT (hereinafter sometimes referred to as “ Plaintiff
23
“ Tahliah”) hereby brings the following causes of action against Defendant SHIA LABEOUF
24
(“ LaBeouf” or “Defendant with knowledge as to herself and otherwise on information and belief,
25
claim and allege as follows:
26
27
28
COMPLAINT
PDF Page 3
1
2
3
4
5
6
7
INTRODUCTION
1.
Shia LaBeoufhurts women. He uses them. He abuses them, both physically and
mentally. He is dangerous. For too long, LaBeoufhas sought to excuse his reprehensible actions as
the eccentricities of a free-thinking “ artist.” Even though his history of violent behavior was well
documented, many in the media have treated LaBeoufas a harmless figure of fun,which has helped
enable him to perpetuate his cycle ofabuse of women over the years. There is nothing funny about
the exploitation of and battering of women. This action has been brought not for personal gain, but
8
to set the recordstraight, and to help ensure that no more women must undergothe abuse that Shia
9
LaBeoufhas inflicted on his prior romantic partners. The days in which LaBeoufcan mistreat and
10
harmwomen with impunityare over.
2
.
11
Tahliah Barnett, professionally known as FKA twigs, is an internationally successful
12
singer, songwriter, and actor. Tahliah was involved in a tumultuous relationship with LaBeouf
13
shortly after they finished working on the motionpicture Honey
14
15
16
17
18
19
20
21
a
charm offensive”
. After LaBeoufhad employed
on Tahliah , a tactic she now knows he used on other women, LaBeouf
convinced her to move in with him. LaBeouf was engaging in grooming
gradually gaining
Tahliah’s trust and confidence with the intent of abusingher. What followed was a livingnightmare
for Tahliah . Over a course of months, LaBeouf engaged in a continuous stream of verbal and
mental abuse toward Tahliah, belittling her and berating her after the slightest perceived “insult
LaBeouf. LaBeouf isolated Tahliah from her friends and family, making it so her daily existence
and routine revolved around LaBeouf and only LaBeouf. His verbal abuse escalated into physical
abuse, during which LaBeouf became increasingly violent toward Tahliah. On one horrific
occasion, around Valentine's Day 2019 , LaBeouf forcibly slammed Tahliah against his car and then
23
strangled her after she was trying to escape from one of his manic tirades . In fact, LaBeouf even
24
admitted to another woman, whom he was cheating on Tahliah with at the time, that he had dragged
25
Tahliah out of his car by her collar. LaBeouf kept Tahliah in a constant state of fear by openly
26
storing live firearms throughout his home, including in the bedroom he shared with Tahliah.
27
Finally, and most dreadfully, LaBeouf knowingly transmitted a serious illness to Tahliah , without
28
ever informing her beforehand that he suffered from this dreadful malady . Tahliah has since learned
COMPLAINT
PDF Page 4
1
that LaBeouf has infected other unsuspecting women with his disease . Simply put LaBeouf's
2 reckless disregard for the health and safety of his partners makes him a danger to women
3 | everywhere.
4
3.
Although Tahliah has suffered greatly , and will bear the scars of LaBeouf's abuse for
5 the rest of her days , she will not be labeled a victim. Instead, Tahliah has triumphed over LaBeouf's
6 abuse and stands ready to hold him accountable for his actions . Together with Karolyn Pho, another
7 survivor of LaBeouf's abuse, Tahliah sought to avoid this action by requesting LaBeouf voluntarily
8
seek the mental health and substance abuse treatment he so desperately needs, and that he make a
9
donation to a domestic violence shelter. Tahliah and Karolyn simply wanted LaBeouf to take
10 affirmative steps toward healing himself and, in turn, to stop his cycle of domestic violence toward
11
12
his future partners and keep them from suffering the same physical, sexual, and mental abuse.
4.
In response to this peaceful overture, LaBeouf played games and downplayed the
13 seriousness of the situation. LaBeouf's attorney cruelly dismissed the sexually transmitted disease
14 LaBeoufhad infected Tahliah with as “not that bad.” LaBeoufattempted to dissuade Karolyn from
15 | allying with Tahliah by sending Karolyn an unsolicited email in which he falsely disparaged
16 Tahliah. LaBeouf also threatened Tahliah, claiming that he was in possession of personal text
17 messages and other information that he could use to embarrass her. In his effort to intimidate
18
Tahliah, LaBeouf engaged
former assistant Noelle O'Reilly into improperly providing
19 him with private and confidential information about Tahliah. With these threats, LaBeouf clearly
20 hoped to terrorize Tahliah into submission and keep her from taking any further action LaBeouf's
21
scare tactics will not work . He has no power over Tahliah anymore .
5
.
Tahliah now brings this action to seek some measure ofjustice not simply for herself
but for the many other women who have been similarly abused by LaBeouf. Tahliah intends to
donate a significant portion of any monies received in this action to charities dedicated to assisting
victims of domestic violence. Never again will another woman be forced to undergo the brutal
treatment and degradation that Tahliah and others experienced at his hands. This case is being
brought on behalf of all those women that LaBeouf has mistreated in the past, and for all those
women who will be spared his abuse in the future.
23
24
25
26
27
28
3
COMPLAINT
PDF Page 5
1
2
3
4
5
6
7
8
PARTIES AND JURISDICTION
6.
Plaintiff Tahliah Barnett is, and at all times relevant was, an individual residing in
London, England, United Kingdom .
7.
Defendant LaBeouf is, and at all times relevant was, an individual residing in the
County ofLos Angeles, State ofCalifornia.
8.
The wrongfulacts by LaBeoufalleged herein occurredinthe County ofLos Angeles,
State of California .
FACTS COMMON TO ALL CAUSES OF ACTION
9
10
LaBeouf's Abuse of Tahliah
11
9.
12
13
14
15
16
17
18
19
20
21
22
23
24
Tahliah first met LaBeoufwhile filming the motion picture “ Honey Boy” in the early
summer of 2018, a film in which both had lead roles. When shooting on the picture wrapped later
that year, the two began a romantic relationship. Tahliah was in a vulnerable and sensitive state at
the time, as she had recently ended a four-year engagement and was recovering from having painful
fibroidtumors removedfrom her uterus
.
10.
Within a week or two of dating, LaBeouf dramatically professed his love for Tahliah .
During the first few months of their relationship , LaBeouf restrained himself to over-the-top
displays of affection, eventually winning Tahliah's trust Once LaBeouf had gained Tahliah's
confidence , her living nightmare began.
11.
Beginning in and around October 2018, LaBeouf convinced Tahliah to go live with
him at his Los Angeles home. Once Tahliah had moved in, LaBeouf began regularly exhibiting
frequent rage and bouts of jealousy toward Tahliah. On a continual basis, he aggressively accused
her of dwelling on her former fiancé (well-known actor Robert Pattinson and also accused Tahliah
of “ rushing” him into a relationship. LaBeouf would inexplicably escalate the most inconsequential
26
disagreements — for example, over matters of taste in artapocalyptic levels, often forcing
Tahliah to stay up all night while he verbally berated her for hours on end about her supposed lack
27
oftaste. LaBeoufwould take something as innocent as Tahliah kissing another man on the cheek in
25
28
4
COMPLAINT
PDF Page 6
1
a music video, or being polite to a waiter, as nothing less than a betrayal, an assault on his manhood,
2
and an existential threat to their relationship.
12.
3
LaBeouf would literally count the kisses Tahliah would give him in a given day and
4
berate her if she fell short of a target number. He would verbally assault Tahliah if he placed his
5
hand in her lap and she failed to immediately reciprocate and place her hand on top of his. He
6
7
would “ end ” their relationship on the slightest imagined grievance and then almost immediately
resurface, desperate to resume it.
13.
8
LaBeouf suffered recurring periods of delusions wherein he armed himself with
9
firearms on the belief “ gang members ” were going to break down his door at any moment , going so
10
far as to sleep with these guns . Tahliah would be trapped in their shared bed for hours at a time
11
without the ability to even get up to go to the bathroom for fear she would be shot by LaBeouf
12
should he wake up suddenly upon her return to bed.
14
.
13
LaBeouf's relentless mental and verbal harassment and mistreatment of Tahliah
14
eventually turned into physical violence . LaBeouf committed physical attacks against Tahliah on
15
multiple occasions, each resulting in personal injuries to Tahliah, not the least of which was
16
LaBeouf's knowing transmission of a serious disease which has forever altered the course of her
17
life.
18
15.
While Tahliah was living with LaBeouf at his Los Angeles home, she remained in
19
constant fear due to the threatening presence of loaded firearms throughout LaBeouf's home.
20
Beginning in November 2018, LaBeouf insisted on keeping his front door unlocked and sleeping
21
with a loaded rifle at their bedside. LaBeouf demanded Tahliah join him while he watched
22
documentaries about murdered women before bed and refused to allow Tahliah to sleep with any
23
24
25
clothing on. In these moments, Tahliah would often text friends inthe middle of the night to devise
a plan to escape LaBeouf's home.
16.
Similarly, when LaBeouf was filming the movie The Tax Collector, in which he
26
played a gangster, he took on the role in real life. During one incident, while Tahliah was driving
27
with him LaBeoufpulled a pistol from a compartment in his car which he boasted to Tahliah was
28
illegal to possess in California. On another occasion, LaBeouf attempted to scare Tahliah by
5
COMPLAINT
PDF Page 7
1
warning her that he pulled out one of his firearms on set and threatened others with it, bragging to
2
Tahliah that he enjoyed “ getting their attention.” LaBeoufmade the horrific boast to Tahliah that, in
3
order to get into “ character” for his role in The Tax Collector, he would drive around neighborhoods
4
in Los Angeles and shoot stray dogs. LaBeouf claimed he killed these dogs because he wanted to
5
know what it felt like to take a life so he could get into the “ mindset” of a killer, like his role in the
6
movie . LaBeouf knew that Tahliah is a great lover of dogs, and that she is very close to her own
7
dog.
8
Tahliah
9
LaBeouf's admission to such wanton animal cruelty profoundly disturbed and terrified
17.
To celebrate the Valentine's Day holiday in February 2019, LaBeouf drove Tahliah
10
to a hotel spa for a romantic evening. However, instead of a night of romance , Tahliah was
11
subjected to a torrent of physical abuse from LaBeouf. After she had gone to bed, Tahliah awoke to
12
LaBeouf towering over her and violently squeezing her body and arms against her will. LaBeouf
13
then grasped his hands around Tahliah's neck and began strangling her while whispering, “If you
14
don't stop you are going to lose me.” Tahliah was so terrified she could not move and lay there
15
frozenwhile LaBeoufcontinuedto harmher.
16
17
18
19
20
21
22
23
24
18 .
The following morning, outside of their hotel, LaBeouf threw Tahliah to the ground .
And as they drove back to LaBeouf's house, LaBeouf drove maniacally , removing his seat belt and
threatening to crash the car unless Tahliah professed her eternal love for him. Tahliah was horrified
by LaBeouf's actions and feared for her life. LaBeouf eventually stopped at a gas station, and
Tahliah desperately attempted to escape from him. However, after Tahliah tried to remove herself
and her belongings from the car, LaBeouf violently attacked Tahliah . While in the gas station
parking lot, he threw Tahliah against the car and attempted to strangle her violently while screaming
in her face. LaBeoufthen forced Tahliah back into his car.
19.
Later, when confronted about this incident by his female friend on September 29,
25
2019 LaBeouf did not deny that he used violence on Tahliah .
26
message that, “ I do remember removing her [ Tahliah from the car in the desert.” LaBeouf stated
27
that he removed Tahliah “ b ]y her arms.” In response, LaBeouf's friend confronted him with a text
28
message stating, “ Shia, you did actually admit to me the incident when you had her [ Tahliah]
6
COMPLAINT
Indeed, LaBeouf admitted it a text
the
PDF Page 8
1
2
collar and were pushingher against the car while she sobbed, and while three male witnesses did
nothingat the gas station was true[. ]”
20.
3
4
5
6
Shortly after the Valentine's Day incident, on February 25, 2019 Tahliah reached
out for help, by texting a close friend and writing, “...
is difficult to say but I am sure you
know. I have been in an abusive relationship that has isolated me. It's worse than you could
imagine.
21.
7
Tahliah also sought the help of a professional therapist, writing to him on February
8
24, “ I have just left an emotionally , physically, and sexually abusive relationship. I have one day
9
out and
very confused and overwhelmed .... am writing this emailbecause I am hoping that
10
by seeking professional help I can stay out of it and carry on with my life.” Tahliah has continued
11
to seek counseling and psychotherapy from this therapist, as she continues to suffer ongoing mental
12
trauma and distress from LaBeouf's relentless abuse.
13
22 .
Tahliah began to slowly distance herself from LaBeouf and his violence . She began
14
this process by planning to escape from LaBeouf when the opportunity arose. However, LaBeouf's
15
fixation on controlling and surveilling Tahliah made the prospect of escape both difficult and
16
dangerous
17
23 .
18
19
20
21
22
23
24
25
26
In and around March 2019, Tahliah attempted to escape from LaBeouf's abuse. One
day she began packing her bags and belongings , intending to leave Los Angeles and LaBeouf.
However , while Tahliah was doing so , LaBeouf showed up unannounced at the rented home where
she was staying . The entire incident was witnessed by Tahliah's housekeeper , who was helping her
at the time. In her own words , the housekeeper had provided sworn testimony that,
“ LaBeouf yelled at [Tahliah ] that she had to come with him. [ Tahliah ] hesitated and remained
where she was in the room . When [ Tahliah ] refused to go with [LaBeouf ], [LaBeouf appeared to
grow angrier and moved toward [Tahliah ] [LaBeouf then violently grabbed [ Tahliah ] and lifted
her off the ground .”
24 .
Tahliah’s housekeeper further relates that “[ a]fter [LaBeouf had lifted [Tahliah]
27
into the air, he forcibly carried her into a separate room. I then heard the door to this room lock
28
from the inside. I tried the door and confirmed that it was locked. [LaBeouf continued to scream
7
COMPLAINT
PDF Page 9
1
at [Tahliah . He yelled so loudly that I could hear him from outside the room. I waited outside the
2
room while this occurred . [LaBeouf kept yelling at [Tahliah] for a considerable amount of time .
3
Eventually, I observed [LaBeouf] open the door and exit the room where he had been keeping
4
[ Tahliah
5
stared at me but did not say anything. "
25
.
6
As he left the room, [ LaBeouf first appeared to notice me watching him.
[ LaBeouf]
Finally, Tahliah’s housekeeper has testified that, “ I quickly went to [ Tahliah ] side
7
to see how she was doing . I observed that [Tahliah] was in a very traumatized state. She appeared
8
to have been crying and her voice was very weak . I asked [Tahliah ] if [LaBeouf had taken her into
9
that room and kept her there against her will . [Tahliah confirmed that [ LaBeouf had indeed done
10
11
12
13
so .” Unfortunately , LaBeouf soon returned, dashing Tahliah’s plans to escape from him.
in and around March 2019 Tahliah began to experience unusual and
painful physical symptoms. Shortly thereafter , Tahliah confronted LaBeouf about her symptoms
and he admitted that he suffered from a sexually transmitted disease which had been diagnosed
26
Beginning
14
years earlier . LaBeouf admitted that he had never told Tahliah about his condition before, even
15
though they had been sexually intimate for many months. Further, LaBeouf admitted that he had
16
experienced a flareup of his disease's symptoms in December 2019, but worked to hide his outward
17
symptoms from Tahliah by applying makeup. Despite experiencing a flareup of his symptoms,
18
LaBeouf continued to engage in sexual relations with Tahliah , further exposing her to his disease .
19
27 .
Shocked and horrified by this revelation, Tahliah consulted with her physician who
20
performed blood work and confirmed that Tahliah had been infected with LaBeouf's disease .
21
Tragically, Tahliah later learned that she was not the first person that LaBeouf had transmitted his
22
disease to
23
24
25
Tahliah discovered that at least one other woman that LaBeouf had been in a
relationship with had contracted the disease from him, and that he had engaged in similar attempts
to hide his condition from that person while engaging in sexual relations.
28 .
Despite his endless mistreatment of Tahliah , LaBeouf had succeeded in isolating her
26
from her friends, family and others that could help extricate her from the toxic relationship.
27
LaBeouf's domineering treatment of Tahliah had allowed him to convince her that he was a victim,
28
that he genuinely loved her and that he wanted to “ repair” their relationship. For the next few
8
COMPLAINT
PDF Page 10
1 months Tahliah engaged in multiple therapy sessions with LaBeouf, in an attempt to salvage their
2
3
relationship. However, LaBeouf's unpredictable and violent behavior did not change. Eventually,
4
his relationship with Tahliah via a text message. Tahliah later learned that LaBeouf had been
5
cheating with another woman during this time. Finally free from LaBeouf, Tahliah began the long
6
and difficult process of healing from his abuse .
after Tahliahrefused his endless streamofcalls and text messages, LaBeoufunceremoniously ended
7
LaBeouf's Prior History of Abuse
8
29.
9
10
11
12
13
14
15
As part of her path toward healing, Tahliah came into contact with Karolyn Pho
(“Karolyn” ), another survivor of LaBeouf's abuse. Karolyn dated LaBeouf during the years 2010 to
2011. Theirs was a well -documented and public relationship .
30 .
Behind that publicity , however LaBeouf subjected Karolyn to the same kind of
abuse, including physical abuse, he inflicted on Tahliah, fueled by his jealous, impulsive , and
irrational ways. For example, just as LaBeouf was fixated on Tahliah's former fiancé and would
accuse her, constantly , of still being emotionally drawn to him, LaBeouf would berate Karolyn for
something as innocuous as “ looking ” at the male waiting staff at a restaurant. LaBeouf would
16 furiously claim that Karolyn was attracted to any male, other than himself, that she happened to be
17
18
looking” at instigating needless traumatic arguments with Karolyn.
31 . Karolyn's experience with LaBeouf was disturbingly similar to Tahliah’s
19
demonstrating his pattern and practice of abusing women . For instance , in February 2012, LaBeouf
20
traveled with Karolyn to New York City for Fashion Week . During their flight east, paid for by
21 Karolyn , LaBeouf angrily berated her for wearing expensive sunglasses and repeatedly humiliated
22
her, causing her to burst into tears in front of other passengers on the airplane. He disappeared the
23 moment he deplaned at JFK airport. Karolyn traveled to their hotel alone, could not find LaBeouf,
24 and went to bed . LaBeouf eventually showed up to the hotel room extremely drunk, waking
25
Karolyn by banging loudly on the door . Karolyn let LaBeouf into their room, where , after babbling
26 | incoherently , he promptly passed out on the couch face up . Fearful that LaBeoufmightchoke on his
27 own vomit in that position , Karolyn helped carry him into a shower , where she sat him upright and
28
turned on the water . LaBeouf continued to sit in this position , mumbling to himself. Believing
COMPLAINT
PDF Page 11
1
LaBeouf was no longer in danger Karolyn returned to bed.
2
LaBeouf on top of her
3
intense pain and leaving multiple bruises, and then headbutted her violently causing her to bleed on
4
the hotel bed.
32 .
5
Later that night, Karolyn awoke to
drunk , naked , wet, and screaming . He held her down by her arms, causing
Likewise, following a party at the Chateau Marmont in early 2011, Karolyn kept
6
LaBeouf from driving home because of how drunk he was . They hailed a taxi. On the ride home to
7
Sherman Oaks, LaBeouf repeatedly berated and verbally assaulted Karolyn in front of the driver,
8
and repeatedly whispered to Karolyn, “ You know I'mgoing to kill you.” Once home , he vomited in
9
the hallway . The next morning, LaBeouf asked Karolyn about the vomit in the hallway , claiming he
10
had " blacked out " and did not remember anything from the prior evening.
33 .
11
12
Karolynhas bravely chosen to ally with Tahliah against LaBeouf, in order to protect
women from ever again having to endure LaBeouf's abuse.
13
LaBeouf's Documented History of Arrests and Violence
14
34 .
15
Over the years, the media has reported on public examples of LaBeouf's violent and
volatile behavior. In 2007, for instance, LaBeouf was arrested and jailed following an altercation
16 with his next-door neighbor in Van Nuys, California. In 2008, LaBeoufnarrowly avoided seriously
17
18
injuring others when his drunk driving caused him to hit another vehicle, resulting in his arrest. In
19
detained by police.
2011, LaBeoufwas involved in a bar fight in Sherman Oaks, California, which resulted in his being
In 2014, LaBeouf attended a performance of the musical Cabaret on
20 Broadway. LaBeouf was extremely drunk during the performance, and caused such a disturbance
21 that he was arrested during the show's intermission . In 2015, LaBeouf's drunk and disorderly
22
behavior resulted his arrest on the streets of Austin , Texas.
23
24
1
See https://people.com/crime/shia-labeouf-arrested-for-dui/
25
2
See https://www.hollywoodreporter.com/news/shia-labeouf-handcuffed-released-bar-96959
26
27
28
3 See https://pagesix.com/2014/06/26/shia-labeouf-arrested-for-disorderly-conduct/
See https://www.usatoday.com/story/life/people/2015/10/09/shia-labeouf-arrested-public
intoxication -in -texas /73694686 /
10
COMPLAINT
PDF Page 12
1
35.
In 2015, the media widely reported on an incident between LaBeouf and his then-
2
girlfriend
3
captured on video by passersby. Among other things, LaBeouf told Goth, “I don’t wanna touch
Mia Goth (“Goth”). While in Germany, LaBeouf’s vicious verbal assault on Goth was
4 you. I don’t wanna be aggressive. This is the kind of shit that makes a person abusive.” LaBeouf,
5 apparently inebriated, blames Goth for “pushing” him. When he eventually leaves the scene,
6 LaBeouf was caught saying, “If I’d have stayed there, I would have killed her.”5
7
36.
As recently as September 24, 2020, LaBeouf was charged by the Los Angeles City
8 Attorney with misdemeanor battery and theft for allegedly using physical violence to steal a man’s
9 hat.6
10
LaBeouf’s Enlists Tahliah’s Former Assistant to Threaten Her
11
37.
From 2017 until 2019, Tahliah employed Noelle O’Reilly (“O’Reilly”) as her
12 personal assistant. Inconnection with her employment with Tahliah, O’Reilly was privy to certain
13 private and confidential information concerning Tahliah’s personal life and career that O’Reilly was
14 obligated not to disclose. However, it has since become clear to Tahliah that O’Reilly repeatedly
15 abused her position of trust by engaging in fraud and outright theft. Moreover, O’Reilly undertook
16 most of her misdeeds while Tahliah was away from her home, living with LaBeouf.
17
38. In August through October 2018, after her own application was denied, and desperate
18 to become a member of the exclusive Soho House chain of clubs, O’Reilly committed identity theft
19 and hacking in order to pose as Tahliah so she could “recommend” herself for a club membership.
20 Once O’Reilly was approved, she then stole from Tahliah by paying for her Soho House
21 membership with Tahliah’s money. All of this was done without Tahliah’s knowledge and consent.
22
23
24
25
5
See https://www.huffpost.com/entry/shia-labeouf-mia-goth-public-fight-
germany_n_55b64e86e4b0224d8832c8e1
26
27
6
See
https://www.nbcnews.com/news/us-news/actor-shia-labeouf-charged-misdemeanor-battery-
petty-theft-n1241857
28
11
COMPLAINT
PDF Page 13
1
39.
As if posing as Tahliah in order to gain a club membership was not enough,
2 stole articles of
designer clothing
3 website Vestiaire Collective.
from Tahliah and sold them for her own
O’Reilly
then directed that the
profit
O’Reilly
via the resale
from these illicit sales be
proceeds
4 directed to her personal account with Vestiaire Collective. For instance, on October 4, 2018,
5 O’Reilly emailed Vestiaire stating, “I have a large collection of designer items, 100-150. I can’t list
6 them all . . . . Account is under this email address.” This collection of
7 Tahliah’s
personal property.
This led to a
viewing appointment
between
“designer
O’Reilly
items” was
and Vestiaire
8 representatives on November 14, 2018, at Tahliah’s house – without Tahliah’s consent and while
9 she was away. The following day, when Vestiaire informed O’Reilly that 15 of the items would
10 need to be returned,
11
40.
O’Reilly
had them returned to her own residence – not Tahliah’s.
Unaware of her
duplicity,
Tahliah confided in
O’Reilly
about LaBeouf’s violent
12 abuse of her. Indeed, O’Reilly took photographs of the bruises that LaBeouf inflicted on Tahliah in
13 February 2019. O’Reilly even sent a text message to Tahliah’s friends to warn them that Tahliah
14 was in an abusive
15 theft, she
began
relationship. However,
soon after Tahliah uncovered
to aid LaBeouf in his intimidation
campaign against
O’Reilly’s deception
and
Tahliah. After Tahliah and
16 Karolyn approached LaBeouf about informally resolving this dispute, which would have involved
17 LaBeouf undergoing intensive psychotherapy and substance abuse treatment in addition to donating
18 to a domestic violence shelter, LaBeouf began an intimidation campaign
19 her from
filing
this lawsuit. LaBeouf stated that
O’Reilly
had
against
provided
Tahliah to
frighten
him with sensitive and
20 confidential information, obtained during O’Reilly’s employment with Tahliah, which he would use
21 to embarrass Tahliah if she ever went public about LaBeouf’s abuse. He also claimed that O’Reilly
22 had provided a statement in which she would claim that Tahliah’s
23 result from LaBeouf’s
physical violence,
February
2019 bruises did not
but were self-inflicted from a strenuous
dancing
session
24 Tahliah had that month. By providing confidential information and false statements to LaBeouf,
25 whom she knew had abused Tahliah, O’Reilly not only violated Tahliah’s trust and confidence but
26 also her own contractual
27
recording
obligations
artist in the music
28 informed Tahliah that
industry
O’Reilly
also
to Tahliah. Tahliah has since
who had also
engaged
employed O’Reilly
spoken
with a
high-profile
as his assistant. That artist
in the theft of his property while under his employ.
12
COMPLAINT
PDF Page 14
1 The fact that LaBeouf would enlist such a
2
3
speaks volumes
41.
disreputable
person to support his intimidation tactics
about his own character, or lack thereof.
Undeterred by LaBeouf’s shameful threats, and determined to keep any more women
4 from being ensnared and abused by such a dangerous man, Tahliah has pressed forward with this
5 action. If LaBeouf will not help himself and address his own demons, Tahliah will do everything in
6 her power to
keep
him from
hurting
7 action. She intends to donate a
8
9
others. Tahliah has nothing to
significant portion
gain professionally
from this
of any monies she receives from LaBeouf to
aimed at helping survivors of domestic abuse. Most importantly, women
are now on notice that LaBeouf is not the tortured artist he portrays himself as: he is a
deserving non-profits
everywhere
10 destructive and dangerous man.
FIRST CAUSE OF ACTION FOR SEXUAL BATTERY
11
12
13
42.
14
paragraphs
15
43.
(BY
PLAINTIFF AGAINST
LABEOUF)
herein by this reference each and every allegation contained in
1 through 41, inclusive, of this Complaint as if set forth fully herein.
16 done without
17
44.
18
45.
19
46.
Plaintiff
re-alleges
LaBeouf’s conduct in
transmitting
a
sexually
transmitted disease to Plaintiff was
Plaintiff’s consent and constitutes sexual battery.
LaBeouf intended to cause and did cause a harmful contact with Plaintiff’s person.
Plaintiff did not consent to LaBeouf’s harmful contact with her person.
As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
20 suffered bodily injuries, severe emotional and mental distress and anguish.
21
47. As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
22 suffered damages, all in amounts according to proof and in excess of the minimum jurisdiction of
23 this Court.
24
25
48.
LaBeouf
performed
the
intentionally, fraudulently, maliciously,
foregoing
and
wrongful
oppressively
acts, conduct, and omissions
in willful and conscious disregard of
Plaintiff. By reason thereof, Plaintiff is
26 Plaintiff’s rights and with the intent and design to damage
27 entitled to recover punitive damages in an amount to be determined at the time of trial.
28
13
COMPLAINT
PDF Page 15
SECOND CAUSE OF ACTION FOR BATTERY
1
2
(BY
3
49.
4
5
paragraphs
Plaintiff
re-alleges
PLAINTIFF AGAINST
herein
by
LABEOUF)
this reference each and every
allegation
contained in
1 through 48, inclusive, of this Complaint as if set forth fully herein.
6
50.
51.
LaBeouf intended to cause and did cause a harmful contact with Plaintiff’s person.
Plaintiff did not consent to LaBeouf’s harmful contact with her person.
7
52.
As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
8 suffered bodily injuries, severe emotional and mental distress and anguish.
9
53. As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
10 suffered damages, all in amounts according to proof and in excess of the minimum jurisdiction of
11 this Court.
12
13
54.
LaBeouf
performed
the
intentionally, fraudulently, maliciously,
foregoing
and
wrongful
oppressively
acts, conduct, and omissions
in willful and conscious disregard of
Plaintiff. By reason thereof, Plaintiff is
14 Plaintiff’s rights and with the intent and design to damage
15 entitled to recover punitive damages in an amount to be determined at the time of trial.
16
THIRD CAUSE OF ACTION FOR ASSAULT
17
(BY PLAINTIFF AGAINST LABEOUF)
18
55.
19
paragraphs
20
56.
21 Plaintiff.
22
57.
23
58.
Plaintiff
re-alleges
herein
by
this reference each and every
allegation
contained in
1 through 54, inclusive, of this Complaint as if set forth fully herein.
LaBeouf acted in a manner such that he intended to cause a harmful
touching
LaBeouf touched and assaulted Plaintiff in a harmful manner.
Plaintiff did not consent to the assaultive conduct committed
by
LaBeouf.
24
59. As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
25 suffered bodily injuries, severe emotional and mental distress and anguish.
26
60. As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
27 suffered damages, all in amounts according to proof and in excess of the minimum jurisdiction of
28 this Court.
14
COMPLAINT
of
PDF Page 16
1
2
61.
LaBeouf
performed
the
intentionally, fraudulently, maliciously,
3 Plaintiff’s
rights
foregoing
and
wrongful
oppressively
and with the intent and design to
damage
acts, conduct, and omissions
in willful and conscious
Plaintiff.
By
disregard
of
reason thereof, Plaintiff is
4 entitled to recover punitive damages in an amount to be determined at the time of trial.
5
FOURTH CAUSE OF ACTION FOR INTENTIONAL INFLICTION OF
6
EMOTIONAL DISTRESS
7
(BY
8
9
62.
paragraphs
10
63.
PLAINTIFF AGAINST
LABEOUF)
and incorporate herein by reference the allegations contained in
1 through 61, inclusive, with the same force and effect as though fully set forth herein.
Plaintiff
reallege
The conduct of LaBeouf as
11 and carried out
by
alleged
above was at all times extreme and outrageous,
LaBeouf with an intention to cause Plaintiff emotional distress and/or with
12 reckless disregard of the probability of causing emotional distress to Plaintiff.
13
64. As a result of the conduct of LaBeouf, as alleged herein, Plaintiff has suffered severe
14 emotional distress and suffering.
15
65.
As a direct and proximate result of the aforesaid acts of LaBeouf, Plaintiff has
16 suffered damages, all in amounts according to proof and in excess of the minimum jurisdiction of
17 this Court.
18
19
66.
LaBeouf
performed
the
intentionally, fraudulently, maliciously,
foregoing
and
wrongful
oppressively
acts, conduct, and omissions
in willful and conscious
disregard
of
20 Plaintiff’s rights and with the intent and design to damage Plaintiff. By reason thereof, Plaintiff is
21 entitled to recover punitive damages in an amount to be determined at the time of trial.
22
FIFTH CAUSE OF ACTION FOR GROSS NEGLIGENCE
23
(BY
LABEOUF)
24
25
paragraphs
26
68.
At all times relevant herein, LaBeouf owed Plaintiff a duty to act with ordinary care.
27
69.
LaBeouf breached his duties to Plaintiff
28
67.
PLAINTIFF AGAINST
diligence
and incorporate herein by reference the allegations contained in
1 through 41, inclusive, with the same force and effect as though fully set forth herein.
Plaintiff
reallege
in his actions toward Plaintiff.
15
COMPLAINT
by failing
to exercise
ordinary
care and due
PDF Page 17
70 .
1
2
LaBeouf's conduct constituted a want of even scant care and an extreme departure
from the ordinary standard of conduct.
71.
3
As a direct and proximate result of LaBeouf's grossly negligent conduct, Plaintiff
4
has suffered damages, all in amounts accordingto proof and inexcess of the minimumjurisdiction
5
of this Court
72.
6
As alleged herein, LaBeouf is guilty of oppression, fraud, and/or malice as defined in
7
Civil Code Section 3294. By reason thereof, Plaintiff is entitled to recover punitive damages in an
8
amount to be determined at the time of trial.
9
10
1.
For compensatorydamages accordingto proof;
11
.
WHEREFORE, Plaintiffprays for judgment against LaBeoufas set forth below:
2
For exemplary and/ or punitive damages as permitted by law;
12
3 .
For cost of suit herein
13
4 .
For such other and further reliefas the court may deemjust and proper;
14
5.
For a trial byjury on all causes ofactionas permittedby law.
15
FREEDMAN+ TAITELMAN, LLP
17
18
19
Dated
December 10, 2020
20
Bryan J. Freedman, Esq.
Sean M. Hardy, Esq.
21
Attorneys forPlaintiffTahliah Barnett
23
24
25
26
27
28
16
COMPLAINT
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