PLEASE READ ARTICLE BELOW FIRST THEN INSTRUCTIONS- Oct. 1, 2017 Marilyn Manson will have to take some time off the road. On Sept. 30, the “Heaven Upside Down” rocker suffered an injury on stage towards the end of his set at NYC’s Hammerstein Ballroom causing him to cut the show short. Manson had to postpone nine tour dates from Boston, Oct. 2, 2017 through Houston, Oct. 14, 2017. The 48-year-old performer was about 45 minutes into his set, performing a cover of Eurythmics’ “Sweet Dreams (Are Made of This),” when it appears that he tried to climb a podium flanked by two large, fake handguns. The prop immediately toppled over, causing the show to come to an abrupt end. After the stage crew lifted the prop back up, Manson reportedly laid on the ground for several minutes, at which point, EMT workers rushed to the backstage area, as venue workers shouted for ice. Manson was taken to a nearby hospital where doctors inserted a plate and 11 screws into his leg and ankle bones. One concert attendee explained what he witnessed: “It happened in the middle of his song ‘Sweet Dreams’. He performed it and all of a sudden he climbed on to the two guns,” he said. “At end of the song he bent over holding one of the poles [on the prop] and tipped over. Then it all went silent and you could hear a pin drop. Everyone rushed to him and there were rumours he was dead. Then they brought out a stretcher and he was taken away.” Another eyewitness said: “From my view point in the front row it didn’t look like he put that much weight on it [the prop] when it started tipping. He tried to brace himself and push it back but it completely tipped and fell on him. Two or three of his crew members rushed to get it off of him quickly.” Manson insists he was not trying to climb on the prop. “I wasn’t trying to climb it,” he said. “It started to fall and I tried to push back and I didn’t get out the way in time. I’m not sure what I hit my head on, but it did fall onto my leg and break the fibula in two places. The pain was excruciating.” “I only recently watched the video of it,” said Manson. “I can see how it could look terrifying. It was terrifying for me, because the truss was not secured properly.” INSTRUCTIONS: Assume that Marilyn Manson has come to your group’s law office intending to file a lawsuit. 1. Prepare a complaint, stating the relevant factual and legal bases in support of Marilyn Manson’s claim. The purpose of a complaint is to put the defendant(s) on notice as to the specific facts and circumstances of the plaintiff’s claim, as well as what type of relief the plaintiff is seeking to obtain from the court. Don’t forget to name the defendants! Include every person or entity you allege to be responsible for causing the legal harm about which the plaintiff, Marilyn Manson, is complaining. For an example of an automobile accident complaint, take a look at http://www.millerandzois.com/Sample_Auto_Accident_Complaint.html. For an example of a slip and fall complaint, take a look at http://www.millerandzois.com/Sample-Slip-and-Fall-Complaint.html. Structure your complaint in this manner. I do not expect you to do a professional job; just set forth the relevant elements of the complaint in layman’s terms. 2. Prepare a set of interrogatories to be served on the defendant(s). What do you need to know to prepare for trial? For an example of Plaintiff’s Interrogatories to Defendant in an automobile accident complaint, see http://www.millerandzois.com/Auto-Accident-Interrogatories-to-Defendant.html For an example of Plaintiff’s Interrogatories to Defendant in a slip and fall complaint, see http://www.millerandzois.com/Sample-slip-fall-interrogatories.html.