Case Document 1 Filed 04/16/14 Page 1 of 13 PageID #2 1 IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF I-IAVVAIIMICHAEL EGAN, CIVI1 Action NovsCOMPLAINTBRYAN JAY SINGER.DefendantPlatnufli MICHAEL EGAN, hereby sues Defendant, BRYAN JAY SINGER, andCase 1:14-cv-00177-SOM-BMK Document 1 Filed 04/16/14 Page 2 of 13PageID #: 2Page 2states the following:INTRODUCTIONDefendant, BRYAN JAY SINGER, manipulated his power, wealth, and position in theentertainment industry to sexually abuse and exploit the underage Plaintiff through the use ofdrugs, alcohol, threats, and inducements which resulted in Plaintiff suffering catastrophicpsychological and emotional injuries. Defendant Singer did so as part of a group of adult malessimilarly positioned in the entertainment industry that maintained and exploited boys in a sordidsex ring. A Hollywood mogul must not use his position to sexually exploit underage actors.JURISDICTION, VENUE, AND PARTIES1.Plaintiff, MICHAEL F. EGAN, III, is a citizen and resident of Clark County,Nevada, and is sui juris.2.Defendant, BRYAN JAY SINGER, is a citizen and resident of the State ofCalifornia and is sui juris.3.This Court has diversity jurisdiction over this action pursuant to 28 U.S.C. §1332(a)(1) because the amount in controversy exceeds $75,000.00 and the action is between citizensof different states.4.A substantial part of the acts, events, or omissions giving rise to Plaintiff’s claimsarose in and around Kailua, Hawaii. Therefore, pursuant to 28 U.S.C. §1391(b)(2), venue isproper in the District of Hawaii.FACTS COMMON TO EACH COUNTPlaintiff Is Introduced To The M & C Estate5.When Plaintiff was in elementary school in the Midwest, he began modeling forprint advertising. As time passed, he performed in school plays and was ultimately encouraged toCase 1:14-cv-00177-SOM-BMK Document 1 Filed 04/16/14 Page 3 of 13PageID #: 3Page 3pursue acting professionally. For a period of time, he moved with his mother to New York andengaged in modeling for print advertising and in television commercials.6.When Plaintiff was 14 or 15, he moved to the Los Angeles, California, area withhis family at the suggestion of his talent manager to further his acting career, and continued tomodel. He dreamed and aspired to have acting become his career.7.Plaintiff attended a very small private high school in the San Fernando Valley inthe Los Angeles, California, area. Plaintiff was short and of a slight stature.8.There were approximately four children in Plaintiff’s grade, one of whom wasScott Shackley (Scott) who Plaintiff considered a close friend. In early or mid-1998, Scottintroduced Plaintiff to his older brother Chad Shackley (Chad) who, upon information and belief,was Scott’s caretaker. Chad resided in a mansion in Encino, California, which was commonlyreferred to as the M & C Estate. Plaintiff would often go to the M & C Estate to visit Scott.Marc Collins-Rector (Collins-Rector) also resided in the M & C Estate as did Chad and Scott.Upon information and belief, a sexual relationship existed between Collins-Rector and Chad.9.At the time, upon information and belief, Collins-Rector was the Chairperson ofthe Board of Directors of an online entertainment business known as Digital EntertainmentNetwork (DEN). Both Chad and Collins-Rector were principals in DEN. Collins-Rector wasinstrumental in promoting and marketing DEN as a commercial venture that would revolutionizetelevision and online entertainment, and DEN was considered at the time to be in the vanguard ofthe growing online entertainment industry. DEN was a well-known enterprise which attracted asignificant number of prominent investors, including persons and organizations that wererenowned in the entertainment industry such as Defendant Singer.Case 1:14-cv-00177-SOM-BMK Document 1 Filed 04/16/14 Page 4 of 13PageID #: 4Page 410.In an attempt to manipulate his compliance with the sexual demands of thoseadults who frequented the M & C Estate, Plaintiff was placed on DEN’s payroll as an actor inRoyal Standard, an online television show broadcast on DEN’s network, and was paidapproximately $1,500.00 per week. Plaintiff additionally was paid approximately $600.00 perweek from different accounts without any designation of job duties, title, or position. Uponinformation and belief, salaries of this nature were paid to many of the teenage males lured to theM & C Estate to have sex with the adults who resided there or visited there for recreational andbusiness purposes. Plaintiff was provided the opportunity to audition for other acting,commercial, and modeling jobs. Plaintiff was promised stock in DEN, was provided withextravagant gifts, and was transported on private jets to attractive locations.Sordid Parties At The M & C Estate11.Upon information and belief, Collins-Rector and Chad hosted many notoriousparties on the grounds of the M & C Estate which were attended by numerous young males whohad been lured to the M & C Estate as well as by DEN investors including Defendant Singer.The parties were typically sordid and featured sexual contact between adult males and the manyteenage boys who were present for the parties. Further, the parties included the distribution ofdrugs and alcoholic beverages to the teenage boys at the party. Upon information and belief, thenature of the parties was well-known and notorious among many men in the Hollywoodentertainment industry.12.Soon after Plaintiff was introduced to Collins-Rector and Chad, he was often toldby them in a bullying manner that they had “gaydar” and knew that Plaintiff was homosexual, acharacterization which Plaintiff, who is heterosexual, categorically denied. He was told that hewas part of the “group”, referring to the numerous young males who were lured to the M & CCase 1:14-cv-00177-SOM-BMK Document 1 Filed 04/16/14 Page 5 of 13PageID #: 5Page 5Estate for the purpose of sexual contact with the adult males who visited the M & C Estateostensibly for recreational and business purposes. He was advised that those adult malescontrolled Hollywood and would destroy his hopes and dreams of an acting career if he did notkeep them happy. They threatened to “eliminate” him and his family, and told him that they weremonitoring not only his phone, but those of his family members, and asserted he would be“destroyed” if he ever disclosed the unconscionable activities that occurred at the Estate.13.Defendant Singer was present for, and participated in, several of these threateningcommunications during which he told Plaintiff how the adults who resided in or frequented theM & C Estate controlled Hollywood and could decide whether Plaintiff’s career aspirations andhopes would be realized. Defendant Singer was also present during times when threats wererelayed to Plaintiff concerning his and his family’s well-being.14.The M & C Estate contained a number of bars and was replete with alcohol anddrugs. The adults at the M & C Estate strenuously pressured the teenagers who were there,including Plaintiff, to ingest the copiously available drugs and alcohol. Plaintiff was often forcedto consume alcoholic beverages and drugs, and was also surreptitiously administered drugs whenthey were placed in beverages that he consumed. Defendant Singer was often present at the M &C Estate when these drug and alcohol-related activities were occurring and knew, or should haveknown, that such was taking place.Defendant Singer Induced Or Coerced Plaintiff Into Sexual Activity15.During the infamous and degenerate parties at the M & C Estate, the adult malesengaged in sexual contacts with the Plaintiff, as well as the other boys present. Plaintiff neverfreely, voluntarily, and knowingly consented to these sexual interactions, and often resisted them.Case 1:14-cv-00177-SOM-BMK Document 1 Filed 04/16/14 Page 6 of 13PageID #: 6Page 616.On several occasions when Plaintiff resisted submitting to sexual contact, Collins-Rector physically and aggressively held Plaintiff down in order to facilitate his sexualvictimization.17.On an occasion when Plaintiff was being resistant to sexual contact, Collins-Rector called him into the master bedroom of the M & C Estate. Collins-Rector pointed a firearmat Plaintiff and threatened to pull the trigger if his resistance to submitting to sexual contactcontinued. Collins-Rector then forcibly locked Plaintiff for a period of time in a gun safe whichwas located in a master bedroom closet.18.Approximately 2–3 months after Collins-Rector began sexually abusing Plaintiff,Defendant Singer was socializing with Collins-Rector around the estate’s swimming pool andPlaintiff was in the pool. In compliance with the “rules” imposed by Collins-Rector that peoplein the pool area were not allowed to wear clothes, Plaintiff was nude as was Defendant Singer.Collins-Rector ordered Plaintiff out of the pool, and Defendant Singer hugged Plaintiff andgrabbed his bare buttocks. They then went to the jacuzzi where Collins-Rector had Plaintiff siton his lap and fondled Plaintiff’s genitals. Collins-Rector then passed Plaintiff to DefendantSinger and Plaintiff was made to sit on Defendant Singer’s lap. Defendant Singer provided analcoholic beverage to Plaintiff and mentioned finding a role for him in an upcoming movie thathe was directing. Defendant Singer told Plaintiff how “this group” controls Hollywood, and thathe was sexy. Defendant Singer masturbated Plaintiff and then performed oral sex upon him.Defendant Singer solicited Plaintiff to perform oral sex upon him which Plaintiff resisted.Defendant Singer flagrantly disregarded Plaintiff’s unwillingness to submit, and forcedPlaintiff’s head underwater to make Plaintiff perform oral sex upon him. When Plaintiff pulledhis head out of the water in order to breathe, Defendant Singer demanded that he continue whichCase 1:14-cv-00177-SOM-BMK Document 1 Filed 04/16/14 Page 7 of 13PageID #: 7Page 7Plaintiff refused. Defendant Singer then forced Plaintiff to continue performing oral sex uponhim outside of the pool, and subsequently forcibly sodomized Plaintiff.19.Defendant Singer visited the estate regularly and continued to sexually assaultPlaintiff. He coerced Plaintiff to masturbate him and to acquiesce to his masturbating Plaintiff,and to each performing oral sex on the other. Defendant Singer also continued to anally rapePlaintiff. Defendant Singer similarly sexually assaulted Plaintiff at other locations.Acts Of Sexual Abuse And Exploitation In Hawaii20.On more than one occasion, Plaintiff was flown to Hawaii when he was 17 yearsold. Two of these trips took place on or between August 1, 1999, and October 31, 1999, duringwhich times his stay lasted roughly one week. Plaintiff stayed in the Paul Mitchell estate inKailua, Hawaii, with Collins-Rector, Shackley, and others, including a number of other juvenilemales. While there, the Paul Mitchell estate contained firearms, drugs, and alcohol. As inCalifornia, there was frequent sexual contact by a number of adult males with teenage males andthe providing of alcoholic beverages and drugs to the young males.21.On each occasion when Plaintiff was in Hawaii, he was required to interact withDefendant Singer while at the Paul Mitchell estate.On more than one occasion, DefendantSinger provided him with drugs, including cocaine, a pill identified as “green triangle” which isbelieved to be a reference to the drug Ecstasy, Xanax, Rohypnol, pain pills believed to beVicodin or Percocet, and alcoholic beverages. Defendant Singer promised acting roles to Plaintiffin an X-Men movie, in commercials, and in other of his projects, and professed that he wouldarrange for Plaintiff to audition for roles and projects in others’ productions. Often when Plaintiffdared to resist the demands of Defendant Singer, he threatened to report Plaintiff’s refusals toCollins-Rector which frightened Plaintiff due to Collins-Rector’s history of threatening harm toCase 1:14-cv-00177-SOM-BMK Document 1 Filed 04/16/14 Page 8 of 13PageID #: 8Page 8him and his family, his previous display of the firearm, his having previously locked Plaintiff in agun closet, and the presence of firearms in the Paul Mitchell estate.22.During the first of the above-referenced trips to Hawaii, Plaintiff was instructedthat he would spend the first two nights in a room with Defendant Singer. During the first night,Plaintiff took a long walk by himself. When he returned to the Paul Mitchell estate, he cameacross Defendant Singer who was in the pool area. Defendant Singer verbally and loudlyconfronted Plaintiff for not having been available for him earlier and demanded that he undress.Defendant Singer frightened Plaintiff by pushing him into the pool, and rebuked Plaintiff for hisattitude and reminded him that he was there to keep people happy. Defendant Singer put ahandful of cocaine against Plaintiff’s nose and forced him to inhale it. Defendant Singer thenprovided Plaintiff with a beverage which he drank which significantly impacted hisconsciousness and his motor skills. Defendant Singer then entered the pool where henonconsensually masturbated Plaintiff and performed oral sex upon him. Defendant Singercaused Plaintiff to rub his erect penis against Defendant Singer’s buttocks. He forced Plaintiff’shead underwater and made Plaintiff orally copulate him. He then caused Plaintiff to get out of thepool and lie face down on a lounge chair. To continue the sexual assault, Defendant Singer spiton Plaintiff’s buttocks, spanked him, and forced a handful of cocaine onto Plaintiff’s face. Hethen anally raped Plaintiff. He subsequently caused them to go to the jacuzzi where he providedanother beverage to Plaintiff. Defendant Singer attempted to insert his penis into Plaintiff’smouth which Plaintiff resisted, but he ultimately was able to force his penis into Plaintiff’smouth. Defendant Singer then assisted Plaintiff to their room where he again anally rapedPlaintiff.Case 1:14-cv-00177-SOM-BMK Document 1 Filed 04/16/14 Page 9 of 13PageID #: 9Page 923.The next night when Plaintiff went to take a shower after forced sexual contactwith another adult, Defendant Singer entered the shower without Plaintiff’s consent andstimulated Plaintiff’s penis with his mouth and hand. Defendant Singer then induced Plaintiff toorally copulate him, followed by Defendant Singer anally raping Plaintiff.Plaintiff did notfreely and voluntarily consent to participate in these sexual acts.24.During the first evening of the second of the above-referenced trips to the PaulMitchell estate in Hawaii, Defendant Singer came to Plaintiff’s room and demanded that Plaintifforally copulate him as well as submit to being orally copulated, and Plaintiff complied. Alsoduring that trip, Defendant Singer anally raped Plaintiff approximately three times, one timebeing so painful that Plaintiff became tearful. On other occasions Defendant Singer compelledPlaintiff to orally copulate him and to be orally copulated by Defendant Singer. Plaintiff did notfreely and voluntarily consent to being sexually assaulted and exploited as he was.25.Upon information and belief, Collins-Rector was criminally prosecuted andconvicted of crimes stemming from the sexual abuse of another young male in a similar mannerand under similar circumstances, and is now a registered sexual offender.26.Upon information and belief, Collins-Rector and Chad have had other civillawsuits filed against them based upon having sexually abused or assaulted other underage malesin a similar manner and under similar circumstances.27.As an actual, legal, and proximate result of the sexual abuse of Plaintiff byDefendant Singer, Plaintiff has suffered, is suffering, and will continue to suffer: a) severepsychological, mental, and emotional injuries and trauma; b) expenses for counseling andtherapy for the psychological, mental and emotional injuries and trauma; c) loss of enjoyment oflife; d) shame, humiliation, and indignity; and e) substantial future expenses for counseling.Case 1:14-cv-00177-SOM-BMK Document 1 Filed 04/16/14 Page 10 of 13PageID #: 10Page 1028.Defendant Singer’s sexual exploitation and abuse of Plaintiff in Hawaii wasaccomplished through the employment of threats, intimidation, the administration of mindaltering substances, and fraudulent inducements to obtain Plaintiff’s submission. DefendantSinger acted wantonly, oppressively, or with such malice as implied a spirit of mischief orcriminal indifference to civil obligations. Defendant Singer’s actions in sexually exploiting andabusing Plaintiff involved or included willful misconduct or that entire want of care which wouldraise the presumption of a conscious indifference to consequences.COUNT I(Intentional Infliction of Emotional Distress)29.Plaintiff repeats and restates the facts set forth in paragraphs 5 through 28 above.30.One or more of the acts of Defendant Singer which caused the egregious harmthat Plaintiff has suffered were intentional, were outrageous, and did cause extreme emotionaldistress to Plaintiff.WHEREFORE, Plaintiff demands against Defendant Singer an amount exceeding$75,000.00 for: 1) compensatory damages; 2) punitive and exemplary damages; 3) costs of thesuit; 4) reasonable attorney’s fees; 5) post-judgment interest as permitted by law; and 6) suchother and further relief as the Court may deem proper.COUNT II(Battery)31.Plaintiff repeats and restates the facts set forth in paragraphs 5 through 28 above.32.On one or more separate occasions, Defendant Singer did act with the intent tocause a nonconsensual, harmful, or offensive contact with Plaintiff, and the contact did occur.WHEREFORE, Plaintiff demands against Defendant Singer an amount exceeding$75,000.00 for: 1) compensatory damages; 2) punitive and exemplary damages; 3) costs of theCase 1:14-cv-00177-SOM-BMK Document 1 Filed 04/16/14 Page 11 of 13PageID #: 11Page 11suit; 4) reasonable attorney’s fees; 5) post-judgment interest as permitted by law; and 6) suchother and further relief as the Court may deem proper.COUNT III33.(Assault)Plaintiff repeats and restates the facts set forth in paragraphs 5 through 28 above.34.On one or more occasions Defendant Singer acted with the intent to cause anonconsensual harmful or offensive contact with, or apprehension thereof by, Plaintiff, andPlaintiff did apprehend an imminent contact of his person by Defendant Singer.WHEREFORE, Plaintiff demands against Defendant Singer an amount exceeding$75,000.00 for: 1) compensatory damages; 2) punitive and exemplary damages; 3) costs of thesuit; 4) reasonable attorney’s fees; 5) post-judgment interest as permitted by law; and 6) suchother and further relief as the Court may deem proper.COUNT IV(Invasion of Privacy by Unreasonable Intrusion)35.Plaintiff repeats and restates the facts set forth in paragraphs 5 through 28 above.36.On one or more occasions Defendant Singer unreasonably intruded into thesolitude or seclusion of Plaintiff by intentionally intruding, physically or otherwise, upon theprivate affairs or concerns of Plaintiff, or upon Plaintiff’s solitude or seclusion, which intrusionswould be highly offensive to a reasonable person. The private affairs or concerns, or solitude orseclusion, of Plaintiff which were unreasonably intruded upon by Defendant Singer include, butare not limited to, his bodily integrity, and his sexual choices.WHEREFORE, Plaintiff demands against Defendant Singer an amount exceeding$75,000.00 for: 1) compensatory damages; 2) punitive and exemplary damages; 3) costs of theCase Document 1 Filed 04/16/14 Page 12 of 13 PageID 12Page 1:sun, 4) neasonable atlomey's fees, 5) post-Judgment mtenest as pennmecl by law. and 6) sucholhel and fiu|l|e1 xelxefas Ihe may deem plopelFILING OFCERTIFICATE OF MERIT37 Punsuanl to HRS Plamufflxas obtamed and 15 filmg a ce111ficaIe ofmen! Will] the Clelk oflhe United Stale: C0lu1 fax the of Hawau The mannel ofIhe filmg of me cemficate of men! 15 subject to a mling by tlus Court pulsllanl to Pla1nI1fFsMotion For Leave Of Conn To F118 Cemficate of Ment Undex Seal In A Tladjtional PaperFormat Plamnff demands a tlus actionDated Apul 16, 2014Respectfully >\Ibl'n1flEURd~Ma|kF Galla hen By Ma1kF GallaghenMaxk GallagherHERMAN LAW3351 Boca Raton BoulevaldBoca Raton. FL 33431hermanlaw comJefi'He1manDennls E. SmgelCase Document 1 Filed 04/16/14 Page 13 of 13 PageID 13Fag: 13Lee G111 Cohen