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Corey liuget v ian danney et al 1

Case -cv- Document Filed Page of Page ID Robinson Brog Leinwand Greene Genovese Gluck P C PETER R GINSBERG Third Avenue th Floor New York NY Telephone Fax Email prg robinsonbrog com pro hac vice admission pending Buchalter A Professional Corporation BARRY A SMITH SBN Wilshire Boulevard Suite Los Angeles CA - Telephone Fax Email bsmith buchalter com Attorneys for Plainti ? UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA COREY LIUGET Case No -cv- Plainti ? COMPLAINT FOR DAMAGES vs DEMAND FOR JURY TRIAL IAN DANNEY and PERFORMANCE ENHANCEMENT PROFESSIONALS INC Defendants Plainti ? Corey Liuget ??Plainti ? ? or ??Liuget ? for his Complaint against Defendants Ian Danney ??Danney ? and Performance Enhancement Professionals Inc ??PEP ? and together with Danney ??Defendants ? alleges as follows BUCHALTER A PROFESSIONAL CORPORATION LOS ANGELES COMPLAINT FOR DAMAGES DEMAND FOR JURY TRIAL BN v Case No -cv- CCase -cv- Document Filed Page of Page ID NATURE OF THE ACTION This is an action by Liuget a professional football player for the Los Angeles Chargers ??Chargers ? of the National Football League ??NFL ? to hold Defendants responsible for Danney ? s malicious and fraudulent conduct in injecting Liuget with a substance that the U S Food and Drug Administration ??FDA ? has not approved and that the NFL Policy on Performance-Enhancing Substances ??Policy ? prohibits a ??Prohibited Substance ? for injecting Liuget with a prescription medication without having a medical license and for administering Liuget with injections without being certi ?ed or licensed to administer injections all without Liuget ? s consent or knowledge of the contents of the injections As a direct result of Defendants ? extreme irresponsible unauthorized and harmful conduct Liuget tested positive for a Prohibited Substance in violation of the Policy and was suspended for the ?rst four games of the NFL Season causing Liuget public humiliation emotional su ?ering and economic damages Liuget is a starting defensive tackle for the Chargers a role he has maintained since the Chargers drafted him in Liuget has never intentionally or knowingly used a Prohibited Substance and prior to the incident herein described has never violated or been subject to discipline or suspension under the Policy Liuget who is feet inches tall and weighs pounds has su ?ered various injuries throughout his playing career including broken metatarsals in both feet During the and NFL Seasons Danney administered post-game treatments to Liuget to help him with the physical demands of playing in the NFL BUCHALTER A PROFESSIONAL CORPORATION LOS ANGELES COMPLAINT FOR DAMAGES DEMAND FOR JURY TRIAL BN v Case No -cv- CCase -cv- Document Filed Page of Page ID On November Danney injected into Liuget ? s feet what Danney said was a high dose of an over-the-counter anti-in ammatory At no time did Danney inform Liuget that he was injecting Liuget with a Prohibited Substance or prescription medication Danny who administers treatment to many professional athletes including NFL players is well aware of familiar with and knowledgeable about the