United States District Court
Central District of California
Vladimir Dracul (A.K.A. Count Dracula, A.K.A. Nosferatu, A.K.A. Grandpa Munster)
Carpathian Mountains, Borgo Pass, Transylvania
- VS -
Los Angeles, California (CA), US
Mr. Dracul, by his attorneys Lugosi & Harker, LLC, files this Amended Complaint against Gwyneth Kate Paltrow (CA, US) and states as follows:
1) Mr. Dracul is a Vampire who obtains nourishment by ingesting human blood through one of the main arteries of live victims.
2) Any impediment to Mr. Dracul's ability to acquire fresh victims would be considered a detriment to his wellbeing.
3) Miss Paltrow's lifestyle website, Goop, which is known for its unconventional products, is currently selling 3.4oz bottles of "Psychic Vampire Repellent." An aerosol that is advertised as "being effective for banishing bad vibes and shielding you from the people who cause them" (eg. vampires and accountants). Ingredients include "love," "moonlight," botanical oils, alcohol, and water.
4) On three separate occasions Mr. Dracul was severely burned around the head, face and genitals after coming into contact with Miss Paltrow's product.
5) First Occasion; On or about February 4, 2017, the plaintiff, Vlad Dracul had assumed the form of a bat and was circling the sky's above Oradea, Romania. At approximately 3:42 a.m. the bat (Mr. Dracul) marked Isabella Petri exiting the rear entrance of "The Crusty Bunz," a local bakery and bikini waxing establishment. Observing an opportunity to feed, Mr. Dracul descended toward Miss Petri and landed on her shoulder, causing Miss Petri to become hysterical. From her pocket-book, Miss Petri produced a bottle of Gwyneth Paltrow's Psychic Vampire Repellent, and sprayed it in Mr. Dracul's direction, disabling him instantly. While he was incapacitated, Miss Petri retrieved a Victor Jetspeed S 10Q, badminton racket, from The Crusty Bunz, and began bouncing Mr. Dracul off the near by tennis wall. This continued for several hours ending only when Miss. Petri's tendonitis began to flare up.
6) Mr. Dracul was severely burned around the upper arm and wing membrane after coming into contact with Gwyneth Paltrow's Psychic Vampire Repellent. The trauma of this encounter has also left the plaintiff with short term memory loss, long term memory loss, memory loss of his memory loss, and gout.
7) Second Occasion; On or about April 13, 2017, Mr. Marcel Renault of 17 Rue de Lacat, Rouen, France exited the lounge of the Hotel Bonaparte after consuming three cognacs, four raspberry liqueurs, two jars of olive juice, six Jello shooters, and one bottle of Gwyneth Paltrow's Psychic Vampire Repellent, which he guzzled on a dare initiated by the bartender. Seeing his prey incapacitated from drink, Mr. Dracul seized upon Mr. Renault and began feeding on his femoral artery. Within minutes of consuming the tainted blood, Mr. Dracul began to feel sharp pains in his abdomen and hair follicles.
8) At approximately 2:10 a.m. Mr Dracul lost control of his bowls in front of several drunken college students, one of whom laughed and threw a shoe at his head.
9) At 3:30 a.m. Mr. Dracul was shooed off the property of Mr. and Mrs. Jean Doisneau, of 17 Rue Colette, after vomiting into their newly installed koi pond.
10) Since this encounter Mr. Dracul suffers from painful urination, sensitive fangs, and flashbacks to a war he never fought in.
11) Third Occasion; On or about July 7, 2017, Mr. Dracul entered the home at 742 Summit Drive, Laguna Beach, California (US), to feed on its owner, Miss Beverly Beverly. Stumbling over the pet kinkajou, Mr. Dracul fell into an open closet causing a disturbance loud enough to drag Miss Beverly from her slumber. Upon seeing a strange man in her hamper, Miss Beverly began throwing nearby objects in Mr. Dracul's direction. Objects consisted of; several hardcover books, a teacup and saucer, a sleeping kinkajou, a wet vibrator, and one bottle of Gwyneth Paltrow's Psychic Vampire Repellent, which burst into shards as it struck Mr. Dracul's right eye.
12) As a direct and proximate result of coming into contact with the defendants product, most of Mr. Dracul's face melted from his skull and leaked into his shoes.
13) Without his face, Mr. Dracul has found it very difficult to find a date, and nearly impossible to shave.
14) As a further direct and proximate result of the defendant's product, the plaintiff now suffers from intense emotional anxiety before feeding.
15) With the manufacture of Gwyneth Paltrow's Psychic Vampire Repellent, the defendant intended to and did cause harm to the undead. Therefore, the plaintiff demands judgement against the defendant, as follows;
1. General damages in an amount to be determined by proof at trial.
2. Medical expenses related to locating and installing a new face.
3. A new pair of black, high-top A01 LED shoes (replacing those ruined by the dripping face).
4. Accompanying Miss Paltrow to the next red carpet event (excluding the Razzie Awards).
5. An autographed picture of Chewbacca
6. Ten pounds of blood sausage
7. Cost of this action
8. Any other and further relief that the court considers proper.
DATED:____________ (Signature) _________________________
I have read the above-entitled action and understand most of the single syllable words. The same is true of my own knowledge, except as to those parts where I lied.
I declare under penalty of perjury that the foregoing is somewhat true and correct and that this declaration was executed while mostly sober.