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David M. Ring, State Bar No. 151124
Brendan P. Gilbert, State Bar No. 273641
2 TAYLOR&RING
1230 Rosecrans Avenue, Suite 360
3 Manhattan Beach, California 90266
Telephone: (310) 209-4100
4 Facsimile: (310) 208-5052
5 Attorneys for Plaintiffs
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF LOS ANGELES
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JANE DOE 1, an individual, and JANE DOE 2,
an individual,
l CASENO.:
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Plaintiffs,
12 vs. COMPLAINT
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JEFFREY COOPER, an individual; SHELLEY l 1. Uniform Voidable Transactions Act
14 COOPER, an individual; BENJAMIN DAVID
COOPER; and DOES 1 through 25,
~) (Civil Code§ 3439 et seq.)
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Defendants.
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COMES NOW, plaintiff JANE DOE 1, an individual, and plaintiff JANE DOE 2, an individual,
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and allege as follows:
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PARTIES, VENUE, AND JURISDICTION
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1. This action follows a pending civil lawsuit for personal injuries entitled Jane Doe 1, et
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al., v. Jeffery Cooper, et al. (Case No. 22VECV01043). The civil lawsuit is currently pending in the
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Superior Court for the County of Los Angeles and is venued in the Northwest District (Van Nuys)
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before the Honorable Huey Cotton in Department A.
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2. At the times of the conduct detailed below, plaintiff JANE DOE 1 and plaintiff JANE
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DOE 2 ("Plaintiffs") were citizens and residents of the State of California living in the County of Los
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Angeles.
COMPLAINT - Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.)
3. Plaintiffs are informed and believe that defendant JEFFREY COOPER is an individual
2 residing in the County of Riverside.
3 4. Plaintiffs are informed and believe that defendant SHELLEY COOPER is an individual
4 residing in the County of Los Angeles.
5 5. Plaintiffs are informed and believe that defendant BENJAMIN DAVID COOPER is an
6 individual residing in the County of Los Angeles.
7 6. Venue and jurisdiction lie properly with this Court, as it is the place where at least one
8 defendant resides and/or where a substantial amount of the events which give rise to this suit occurred.
9 7. The true names and capacities of each defendant designated herein as DOES 1 through
10 25, inclusive, whether an individual, business, public entity, or some other entity, are presently unknown
11 to Plaintiff, who therefore sues said defendants by such fictitious names, pursuant to Code of Civil
12 Procedure section 474. Plaintiff is informed and believes, and on such information and belief, alleges
13 that each DOE defendant is responsible in some actionable manner for the events alleged herein.
14 Plaintiff will amend her complaint to state the true names and capacities of said defendants when the
15 same have been ascertained.
16 8. At all times herein mentioned, each of the defendants sued herein as DOES 1 through 25,
17 inclusive, were the agents, servants, employees and/or joint venturers of each of the remaining
18 defendants and were at all times acting within the course and scope of such agency, employment and/or
!9 venture with the full knowledge, consent, authority, ratification and/or permission of each of the
20 remaining defendants.
21 9. Wherever appearing in this complaint, each and every reference to defendants, or any of
22 them, is intended to include, and shall be deemed to include, all fictitiously named defendants.
23 UNDERLYING FACTUAL ALLEGATIONS
24 10. In Fall 2006, plaintiff JANE DOE 1 was sexually assaulted by JEFFREY COOPER.
25 11. From 2012 through 2016, JEFFREY COOPER repeatedly sexually assaulted plaintiff
26 JANE DOE 2.
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COMPLAINT- Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.)
12. In 2018, Plaintiffs retained Taylor & Ring to represent them in a civil lawsuit against
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JEFFREY COOPER. JEFFREY COOPER was aware that Plaintiffs had retained counsel to represent
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them in a civil lawsuit for the sexual assault he committed against them.
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13. On June 18, 2018, JEFFREY COOPER was arrested related to his sexual assaults of
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Plaintiffs.
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14. On November 26, 2018, a criminal grand jury hearing was commenced against
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JEFFREY COOPER related to his sexual assault of Plaintiffs. The grand jury indicted JEFFREY
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COOPER on all counts and allegations in the prosecutor's proposed indictment.
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15. The criminal trial took place in May 2022. The jury convicted COOPER on multiple
counts of the indictment related to Plaintiff Jane Doe 1. JEFFREY COOPER was sentenced to 6 years
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in state prison.
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16. Plaintiffs filed a civil lawsuit against JEFFREY COOPER on July 25, 2022. JEFFREY
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COOPER was served with the lawsuit on August 5, 2022.
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17. As a result of his criminal conviction, JEFFREY COOPER is barred from arguing
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liability with respect to Plaintiff Jane Doe 1 in her civil lawsuit against him. Thus, her civil case against
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JEFFREY COOPER will be for damages only.
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18. Plaintiffs are informed and believe that since at least 2020 and through the present,
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JEFFREY COOPER has transferred significant assets to an irrevocable trust in the Cook Islands in an
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effort to avoid any debt that would be owed following a judgment being entered against him at the
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conclusion of Plaintiffs' civil lawsuit. These assets include, but are not limited to, millions of dollars
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being transferred to the irrevocable trust in the Cook Islands. SHELLY COOPER and BENJAMIN
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DAVID COOPER are the beneficiaries of this irrevocable trust.
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19. Plaintiffs only recently learned of these fraudulent transfers through discovery in the
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civil lawsuit. As a result, Plaintiffs bring this lawsuit to void the fraudulent and illegal transfers of
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assets to irrevocable trust in the Cook Islands and to prevent any further attempts to make any transfers.
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Ill
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Ill
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COMPLAINT- Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.)
FIRST CAUSE OF ACTION
2 Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.)
3 [By all Plaintiffs against all Defendants]
4 20. Plaintiffs repeat, replead, and reallege paragraphs 1 through 16, and incorporates the
5 allegations thereof as though fully set forth herein.
6 21. Under the California Uniform Voidable Transactions Act ("UVTA"), a creditor may
7 seek to, in part, void the transfer of assets to the extent necessary to satisfy the creditor's claim; get an
8 attachment or other provisional remedy against the asset transferred or other property of the transferee;
9 get an injunction against further disposition or transfer of assets; and/or get any other relief the
10 circumstances may require. (Code of Civil Proc., §3439.07).
11 22. The debts and obligations owed by defendant JEFFREY COOPER to Plaintiffs were
12 incurred well before JEFFREY COOPER transferred assets to an irrevocable trust in the Cook Islands.
13 SHELLEY COOPER and BENJAMIN DAVID COOPER are beneficiaries of this irrevocable trust.
14 Plaintiffs filed their civil lawsuit against JEFFREY COOPER to recoup the debts and obligations owed
15 to them well before COOPER transferred assets to the irrevocable trust. As such, Plaintiffs are creditors
16 under the UVTA with all rights and remedies available under the law.
17 23. Plaintiffs are informed and believe that the conduct and actions of defendants JEFFREY
18 COOPER, SHELLEY COOPER, BENJAMIN DAVID COOPER and DOES 1-25 were fraudulent and
19 in direct violation of the UVTA. Thus, the prior transfers of the assets to the irrevocable trust in the
20 Cook Island are voidable. Furthermore, any further attempt by the defendants to hinder, delay, and
21 defraud Plaintiffs by transferring assets to this irrevocable trust in the Cook Islands would be illegal,
22 fraudulent, and in direct violation of the law.
23 24. As a direct and proximate result of the above-described wrongful and intentional
24 conduct of the defendants, and each of them, Plaintiffs are being deprived of the ability to be
25 compensated for the significant harms and losses caused by the actions of defendant JEFFREY
26 COOPER as the defendants have engaged, and are engaging in, wrongful conduct to put assets and
27 wealth that would otherwise be reachable and collectable to enforce a judgment against defendant
28 JEFFREY COOPER beyond the reach of creditors, and specifically, Plaintiffs.
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COMPLAINT- Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.)
PRAYER
2 WHEREFORE, Plaintiffs pray for judgment against Defendants, and each of them, as follows:
3 1. For avoidance of the transfer(s) to the extent necessary to satisfy the Plaintiffs' claims;
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2. For orders of attachment and other provisional remedies against the transferred assets;
5 3. An injunction against further disposition of assets;
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4. For a judicial lien on the Defendants' transferred assets;
7 5. For prejudgment interest, according to proof;
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6. For costs of suit incurred herein, according to proof;
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7. For such other and further relief as the Court may deem proper.
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11 Dated: April 17, 2024 TAYLOR&RING
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By:
14 Davfd M. Ring
Brendan P. Gilbert
15 Attorneys for Plaintiffs
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COMPLAINT - Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.)
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David M. Ring, State Bar No. 151124 Brendan P. Gilbert, State Bar No. 273641 2 TAYLOR&RING 1230 Rosecrans Avenue, Suite 360 3 Manhattan Beach, California 90266 Telephone: (310) 209-4100 4 Facsimile: (310) 208-5052 5 Attorneys for Plaintiffs 6 SUPERIOR COURT OF THE STATE OF CALIFORNIA 7 FOR THE COUNTY OF LOS ANGELES 8 9 JANE DOE 1, an individual, and JANE DOE 2, an individual, l CASENO.: 11 Plaintiffs, 12 vs. COMPLAINT 13 JEFFREY COOPER, an individual; SHELLEY l 1. Uniform Voidable Transactions Act 14 COOPER, an individual; BENJAMIN DAVID COOPER; and DOES 1 through 25, ~) (Civil Code§ 3439 et seq.) ~ 15 Defendants. ~ 16 17 18 19 - - - - -- - - - - - -- - - - - l COMES NOW, plaintiff JANE DOE 1, an individual, and plaintiff JANE DOE 2, an individual, 20 and allege as follows: 21 PARTIES, VENUE, AND JURISDICTION 22 1. This action follows a pending civil lawsuit for personal injuries entitled Jane Doe 1, et 23 al., v. Jeffery Cooper, et al. (Case No. 22VECV01043). The civil lawsuit is currently pending in the 24 Superior Court for the County of Los Angeles and is venued in the Northwest District (Van Nuys) 25 before the Honorable Huey Cotton in Department A. 26 2. At the times of the conduct detailed below, plaintiff JANE DOE 1 and plaintiff JANE 27 DOE 2 ("Plaintiffs") were citizens and residents of the State of California living in the County of Los 28 Angeles. COMPLAINT - Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.) 3. Plaintiffs are informed and believe that defendant JEFFREY COOPER is an individual 2 residing in the County of Riverside. 3 4. Plaintiffs are informed and believe that defendant SHELLEY COOPER is an individual 4 residing in the County of Los Angeles. 5 5. Plaintiffs are informed and believe that defendant BENJAMIN DAVID COOPER is an 6 individual residing in the County of Los Angeles. 7 6. Venue and jurisdiction lie properly with this Court, as it is the place where at least one 8 defendant resides and/or where a substantial amount of the events which give rise to this suit occurred. 9 7. The true names and capacities of each defendant designated herein as DOES 1 through 10 25, inclusive, whether an individual, business, public entity, or some other entity, are presently unknown 11 to Plaintiff, who therefore sues said defendants by such fictitious names, pursuant to Code of Civil 12 Procedure section 474. Plaintiff is informed and believes, and on such information and belief, alleges 13 that each DOE defendant is responsible in some actionable manner for the events alleged herein. 14 Plaintiff will amend her complaint to state the true names and capacities of said defendants when the 15 same have been ascertained. 16 8. At all times herein mentioned, each of the defendants sued herein as DOES 1 through 25, 17 inclusive, were the agents, servants, employees and/or joint venturers of each of the remaining 18 defendants and were at all times acting within the course and scope of such agency, employment and/or !9 venture with the full knowledge, consent, authority, ratification and/or permission of each of the 20 remaining defendants. 21 9. Wherever appearing in this complaint, each and every reference to defendants, or any of 22 them, is intended to include, and shall be deemed to include, all fictitiously named defendants. 23 UNDERLYING FACTUAL ALLEGATIONS 24 10. In Fall 2006, plaintiff JANE DOE 1 was sexually assaulted by JEFFREY COOPER. 25 11. From 2012 through 2016, JEFFREY COOPER repeatedly sexually assaulted plaintiff 26 JANE DOE 2. 27 28 2 COMPLAINT- Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.) 12. In 2018, Plaintiffs retained Taylor & Ring to represent them in a civil lawsuit against 2 JEFFREY COOPER. JEFFREY COOPER was aware that Plaintiffs had retained counsel to represent 3 them in a civil lawsuit for the sexual assault he committed against them. 4 13. On June 18, 2018, JEFFREY COOPER was arrested related to his sexual assaults of 5 Plaintiffs. 6 14. On November 26, 2018, a criminal grand jury hearing was commenced against 7 JEFFREY COOPER related to his sexual assault of Plaintiffs. The grand jury indicted JEFFREY 8 COOPER on all counts and allegations in the prosecutor's proposed indictment. 9 15. The criminal trial took place in May 2022. The jury convicted COOPER on multiple counts of the indictment related to Plaintiff Jane Doe 1. JEFFREY COOPER was sentenced to 6 years 11 in state prison. 12 16. Plaintiffs filed a civil lawsuit against JEFFREY COOPER on July 25, 2022. JEFFREY 13 COOPER was served with the lawsuit on August 5, 2022. 14 17. As a result of his criminal conviction, JEFFREY COOPER is barred from arguing 15 liability with respect to Plaintiff Jane Doe 1 in her civil lawsuit against him. Thus, her civil case against 16 JEFFREY COOPER will be for damages only. 17 18. Plaintiffs are informed and believe that since at least 2020 and through the present, 18 JEFFREY COOPER has transferred significant assets to an irrevocable trust in the Cook Islands in an 19 effort to avoid any debt that would be owed following a judgment being entered against him at the 20 conclusion of Plaintiffs' civil lawsuit. These assets include, but are not limited to, millions of dollars 21 being transferred to the irrevocable trust in the Cook Islands. SHELLY COOPER and BENJAMIN 22 DAVID COOPER are the beneficiaries of this irrevocable trust. 23 19. Plaintiffs only recently learned of these fraudulent transfers through discovery in the 24 civil lawsuit. As a result, Plaintiffs bring this lawsuit to void the fraudulent and illegal transfers of 25 assets to irrevocable trust in the Cook Islands and to prevent any further attempts to make any transfers. 26 Ill 27 Ill 28 Ill 3 COMPLAINT- Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.) FIRST CAUSE OF ACTION 2 Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.) 3 [By all Plaintiffs against all Defendants] 4 20. Plaintiffs repeat, replead, and reallege paragraphs 1 through 16, and incorporates the 5 allegations thereof as though fully set forth herein. 6 21. Under the California Uniform Voidable Transactions Act ("UVTA"), a creditor may 7 seek to, in part, void the transfer of assets to the extent necessary to satisfy the creditor's claim; get an 8 attachment or other provisional remedy against the asset transferred or other property of the transferee; 9 get an injunction against further disposition or transfer of assets; and/or get any other relief the 10 circumstances may require. (Code of Civil Proc., §3439.07). 11 22. The debts and obligations owed by defendant JEFFREY COOPER to Plaintiffs were 12 incurred well before JEFFREY COOPER transferred assets to an irrevocable trust in the Cook Islands. 13 SHELLEY COOPER and BENJAMIN DAVID COOPER are beneficiaries of this irrevocable trust. 14 Plaintiffs filed their civil lawsuit against JEFFREY COOPER to recoup the debts and obligations owed 15 to them well before COOPER transferred assets to the irrevocable trust. As such, Plaintiffs are creditors 16 under the UVTA with all rights and remedies available under the law. 17 23. Plaintiffs are informed and believe that the conduct and actions of defendants JEFFREY 18 COOPER, SHELLEY COOPER, BENJAMIN DAVID COOPER and DOES 1-25 were fraudulent and 19 in direct violation of the UVTA. Thus, the prior transfers of the assets to the irrevocable trust in the 20 Cook Island are voidable. Furthermore, any further attempt by the defendants to hinder, delay, and 21 defraud Plaintiffs by transferring assets to this irrevocable trust in the Cook Islands would be illegal, 22 fraudulent, and in direct violation of the law. 23 24. As a direct and proximate result of the above-described wrongful and intentional 24 conduct of the defendants, and each of them, Plaintiffs are being deprived of the ability to be 25 compensated for the significant harms and losses caused by the actions of defendant JEFFREY 26 COOPER as the defendants have engaged, and are engaging in, wrongful conduct to put assets and 27 wealth that would otherwise be reachable and collectable to enforce a judgment against defendant 28 JEFFREY COOPER beyond the reach of creditors, and specifically, Plaintiffs. 4 COMPLAINT- Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.) PRAYER 2 WHEREFORE, Plaintiffs pray for judgment against Defendants, and each of them, as follows: 3 1. For avoidance of the transfer(s) to the extent necessary to satisfy the Plaintiffs' claims; 4 2. For orders of attachment and other provisional remedies against the transferred assets; 5 3. An injunction against further disposition of assets; 6 4. For a judicial lien on the Defendants' transferred assets; 7 5. For prejudgment interest, according to proof; 8 6. For costs of suit incurred herein, according to proof; 9 7. For such other and further relief as the Court may deem proper. 10 11 Dated: April 17, 2024 TAYLOR&RING 12 13 By: 14 Davfd M. Ring Brendan P. Gilbert 15 Attorneys for Plaintiffs 16 17 18 19 20 21 22 23 24 25 26 27 28 5 COMPLAINT - Uniform Voidable Transactions Act (Civil Code§ 3439 et seq.)