A Louisiana woman left paralyzed by a robber who shot her after watching "Natural Born Killers" claims Hollywood is partly to blame. Patsy Byers was working at the Time Saver store when 18- year-old Sarah Edmondson came in, shot her and stole money from the cash register. Edmondson later told police that she and her boyfriend Benjamin Darrus took drugs and went on a shooting spree after repeatedly watching the Oliver Stone movie. In her lawsuit, Byers' claims Stone, Warner Bros. and several other defendants knew or should have known that the movie "would cause and inspire people such as the defendants to commit crimes." The case has pitted best- selling novelist John Grisham against Stone. Grisham has urged lawsuits against the movie, claiming it glamorizes casual mayhem and bloodlust. Grisham was friends with Bill Savage, a businessman fatally shot by Edmondson and Darrus.

TWENTY-FIRST JUDICIAL DISTRICT COURT
PARISH OF TANGIPAHOA
STATE OF LOUISIANA

NUMBER: 9502213
DIV."C"


PATSY ANN BYERS, ET AL

VERSUS

SARAH EDMONDSON, ET AL


FILED:


PLAINTIFFS' SECOND SUPPLEMENTAL AND AMENDING
PETITION FOR DAMAGES


The Second Supplemental and Amending Petition for Damages of
Patsy Ann Byers and her husband, Lonnie Wayne Byers, individually
and as natural tutor for Jacob Eugene Byers, age 13, Joshua Noah
Byers, age 4, and Ladonna Marie Byers, domiciled in Tangipahoa
Parish, with respect represent:

I.

Made defendants herein are the following:

1. SARAH EDMONDSON, of lawful age of majority and a resident
of Louisiana who can be served in the Tangipahoa Parish Jail.

2. BENJAMIN DARRUS, of lawful age of majority and a resident of
Louisiana who can be served in the Tangipahoa Parish Jail.

3. JAMES E. EDMONDSON, of lawful age of majority and resident
of 601 North 13th Street, Muskogee, Oklahoma 74401-3724

4. SUZANNE EDMONDSON, of lawful age of majority and resident
of 601 North 13th Street, Muskogee, Oklahoma 74401-3724

5. USAA CASUALTY INSURANCE COMPANY, San Antonio,
Texas, 78288, a foreign company doing business in Louisiana,
United Services Automobile Association a/k/a, d/b/a and USAA Life
Insurance Company, a/k/a, d/b/a and USAA General Indemnity
Company, (hereinafter USAA)

6. UNITED SERVICES AUTOMOBILE ASSOCIATION, San
Antonio, Texas, a foreign company doing business in Louisiana,
a/k/a, d/b/a, and USAA Life Insurance Company, a/k/a, d/b/a and
USAA General Indemnity Company a/k/a, d/b/a and USAA Casualty
Insurance Company, (hereinafter USAA)

7. USAA GENERAL INDEMNITY COMPANY, San Antonio,
Texas, a foreign company doing business in Louisiana, a/k/a, d/b/a,
and USAA Life Insurance Company, a/k/a, d/b/a and USAA General
Indemnity Company a/k/a, d/b/a and USAA Casualty Insurance
Company, (hereinafter USAA)

8. WARNER HOME VIDEO, INC., a/k/a and d/b/a and Warner
Brothers, a/k/a and d/b/a and Warner Brothers, Inc., a/k/a and d/b/a
and Time Warner Entertainment Company, L.P., a/k/a and d/b/a and
Time Warner Entertainment Company, Inc., a/k/a and d/b/a and Time
Warner Entertainment Company, a/k/a and d/b/a and Warner Home
Video, a/k/a and d/b/a and Time Warner, Inc., a/k/a and d/b/a and
Time Warner, 4000 Warner Boulevard, Burbank, California 91505, a
foreign corporation and/or partnership doing business in the State of
Louisiana, (hereinafter Hollywood Defendants)

9. WARNER BROTHERS, INC., a/k/a and d/b/a and Warner
Brothers, a/k/a and d/b/a and Warner Home Video, Inc. a/k/a and
d/b/a and Time Warner Entertainment Company, L.P., a/k/a and d/b/a
and Time Warner Entertainment Company, Inc., a/k/a and d/b/a and
Time Warner Entertainment Company, a/k/a and d/b/a and Warner
Home Video, a/k/a and d/b/a and Time Warner, Inc., a/k/a and d/b/a
and Time Warner, 4000 Warner Boulevard, Burbank, California
91505, a foreign corporation and/or partnership doing business in the
State of Louisiana, (hereinafter Hollywood Defendants)

10. TIME WARNER ENTERTAINMENT COMPANY, L.P., a/k/a
and d/b/a and Warner Brothers, a/k/a and d/b/a and Warner Brothers,
Inc., a/k/a and d/b/a and Warner Home Video, Inc. a/k/a and d/b/a and
Time Warner Entertainment Company, Inc., a/k/a and d/b/a and Time
Warner Entertainment Company, a/k/a and d/b/a and Warner Home
Video, a/k/a and d/b/a and Time Warner, Inc., a/k/a and d/b/a and
Time Warner, 4000 Warner Boulevard, Burbank, California 91505, a
foreign corporation and/or partnership doing business in the State of
Louisiana, 500 N. Brand Boulevard, Glendale, CA 91203 and N.Y.,
N.Y., a Delaware Limited Partnership doing business in Louisiana,
(hereinafter Hollywood Defendants)

11. TIME WARNER, INC., a/k/a and d/b/a and Warner Brothers,
a/k/a and d/b/a and Warner Home Video, Inc. a/k/a and d/b/a and Time
Warner Entertainment Company, Inc., a/k/a and d/b/a and Time
Warner Entertainment Company, a/k/a and d/b/a and Warner Home
Video, a/k/a and d/b/a and Time Warner, a/k/a and d/b/a and Warner
Brothers, Inc., a/k/a and d/b/a and Time Warner Entertainment
Company, L.P., a/k/a and d/b/a and Warner Home Video, Inc., 4000
Warner Boulevard, a Delaware corporation doing business in
Louisiana, (hereinafter Hollywood

11. REGENCY ENTERPRISES, a/k/a and d/b/a and Regency
Enterprises, Inc., a California, doing business in the State of
Louisiana, (hereinafter Hollywood Defendants)

12. ALCOR FILMS, a/k/a and d/b/a and Alcor Films,Inc., upon
information and belief, a foreign corporation doing business in the
State of Louisiana, (hereinafter Hollywood Defendants)

13. J.D. PRODUCTIONS, a/k/a and d/b/a and J.D. Productions, Inc,
upon information and belief, a California corporation doing business
in the State of Louisiana, (hereinafter Hollywood Defendants)

14. OLIVER STONE, upon information and belief, a resident of
California doing business in Louisiana (hereinafter Hollywood
Defendants)

II.

On March 8, 1995 in Ponchatoula, Louisiana, Sarah Edmondson and
Benjamin Darrus acting together shot and seriously wounded Patsy
Ann Byers during an armed robbery of a Time Saver convenience
store in Ponchatoula, Louisiana.

IIA.
Upon information and belief, Sarah Edmondson and Benjamin Darrus
shot Patsy Ann Byers with a weapon they obtained from a cabin
owned by Sarah's parents, James E. Edmondson and Suzanne
Edmondson.

IIB.
Upon information and belief, defendants James E. Edmondson and
Suzanne Edmondson were insured by one or more insurance
companies, more particularly, but not exclusively, the companies
hereinabove referred to as USAA.

IIC.
Upon information and belief, defendants Benjamin Darrus and Sarah
Edmondson, went upon a crime spree culminating in the shooting and
permanent injury to Patsy Ann Byers as a result of seeing and
becoming inspired by the movie "Natural Born Killers" produced,
directed and distributed by the Hollywood defendants.

III.

Patsy Ann Byers' lawful husband in Lonnie Wayne Byers. She has
two minor children, Jacob Eugene Byers and Joshua Noah Byers, and
one major child, Ladonna Marie Byers.

IV.

As a result of the shooting, Patsy Ann Byers was hospitalized in
Houston, Texas paralyzed from the chest down and on a breathing
machine. She has suffered grievous injuries necessitating astronomical
medical bills and complete and permanent disability.

V.

The incident sued on herein is inexplicable without resort to the
presumption of negligence and the applicability of the doctrine of res
ipsa loquitur in view of the fact that the defendants, Sarah Edmondson
and Benjamin Darrus shot Patsy Ann Byers with no remorse and left
her to die on the floor of the convenience store.

V(A).
Defendant, Sarah Edmondson is further negligent more particularly,
but not exclusively, in shooting Patsy Ann Byers, in failing to attempt
to obtain for her medical assistance, and for such other negligence as
will be learned during discovery and shown at trial of this matter.

V(B).
Defendant Benjamin Darrus is further negligent, more particularly but
not exclusively, in accompanying Sarah Edmondson upon her
shooting spree, in encouraging her to engage in same, in assisting her,
in driving away, in failing to obtain medical assistance for Patsy Ann
Byers, and for such other negligence as will be learned during
discovery and shown at trial of this matter.

V(C).
James E. Edmondson and Suzanne Edmondson are negligent, more
particularly, but not exclusively, in allowing a loaded weapon to be
accessible to defendants, Sarah Edmondson and Benjamin Darrus,
particularly in light of their knowledge of the wild recklessness and
potential for danger to others each presented, and for such other
negligence as shall be learned during discovery and shown at trial of
this matter.

V(D).
USAA are liable as the insurers of James E. Edmondson and Suzanne
Edmondson who provided coverage for liability of the nature asserted
herein against such defendant. Said insurance inures to the benefit of
plaintiffs under the provisions of Louisiana Direct Action Statute, La.
R.S. 22:655, entitling plaintiffs to maintain this direct action against
said defendant insurer, and thereby rendering said defendant insurer
liable, in solido, with defendants, for damages as sued for herein.

V(E).
All of the Hollywood defendants are liable, more particularly, but not
exclusively for, distributing a film which they knew or should have
known would cause and inspire people such as defendants, Sarah
Edmondson and Benjamin Darrus, to commit crimes such as the
shooting of Patsy Ann Byers, and for producing and distributing a
film which glorified the type of violence defendants committed against
Patsy Ann Byers by treating individuals who commit such violence as
celebrities and heros, as well as for such other negligence as will be
learned during discovery and shown at trial of this matter.

VI.

Patsy Ann Byers is entitled to recover from the defendants for their
joint negligence and actions as follows:

A.Past, present, and future loss of income; B.Past, present, and
future medical expense; C.Past, present, and future loss of enjoyment
of life; D.Past, present, and future mental and physical pain and
suffering; E.Past, present and future disability and scarring.


VII.

Lonnie Wayne Byers, individually and as tutor of the minor children,
Jacob Eugune Byers and Joshua Noah Byers, and Ladonna Marie
Byers are entitled to loss of consortium, society and friendship, as
well as loss of support from their wife and mother respectfully.

VIII.

Patsy Ann Byers and Lonnie Wayne Byers, individually and as tutor
of the minor children, Jacob Eugene Byers and Joshua Noah Byers,
and Ladonna Marie Byers, in accordance with Louisiana Code of Civil
Procedure Article 2315 et seq., assert action against the defendants,
Sarah Edmondson, Benjamin Darrus, James E. Edmondson, Suzanne
Edmondson, USAA Casualty Insurance Company, United Services
Automobile Association, USAA General Indemnity Company,
Warner Home Video, Inc., Warner Brothers, Inc., Time Warner
Entertainment Company, L.P., Regency Enterprises, Alcor Films,
J.D. Productions, and Oliver Stone, in solido, seeking all such
damages as may be reasonable in the premises, including damages for
loss of income and ability to earn same, pain and suffering, grief,
mental anguish, loss of future support, loss of enjoyment of life and
for loss of consortium, service and society.

IX.

The amount sued upon is above the amount necessary for a jury trial
under the Louisiana Code of Civil Procedure.

X.

Petitioners are without funds and are unable to pay the costs of court
in advance, or as they accrue, or to furnish security and, therefore,
desire that they be permitted to proceed forma pauperis.

WHEREFORE, PETITIONERS PRAY, that they be allowed to
proceed in forma pauperis, for Leave of Court to file this amended
petition, and that defendants be served with a copy of this amended
petition, and cited to appear and answer same, and after due
proceedings had, that there be judgment in favor of plaintiffs, Patsy
Ann Byers and Lonnie Wayne Byers, individually and as tutor of their
minor children, Jacob Eugene Byers and Joshua Noah Byers, and one
major child, Ladonna Marie Byers, and against defendants, Sarah
Edmondson and Benjamin Darrus, James E. Edmondson, Suzanne
Edmondson, USAA Casualty Insurance Company, United Services
Automobile Association, USAA General Indemnity Company,
Warner Home Video, Inc., Warner Brothers, Inc., Time Warner
Entertainment Company, L.P., Regency Enterprises, Alcor Films,
J.D. Productions, Oliver Stone, jointly and in solido, in an amount
reasonable to compensate them for their damages, together with
interest thereon from date of judicial demand until paid, all costs of
these proceedings, and for all general and equitable relief.

Respectfully Submitted:

Joseph H. Simpson, Bar Roll #08259
305 East Mulberry Street
Post Office Box 1017
Amite, Louisiana 70422
Telephone: (504) 748-8362

AND

Rick A. Caballero
Bar Roll Number 1744
8201 Jefferson Highway
Baton Rouge, Louisiana 70809
Telephone: (504) 929-7481
Telecopier: (504) 924-4519

AND

Ron Macaluso
200 North Cate Street
Hammond, Louisiana 70404
Telephone: (504) 345-8058

SERVICE INFORMATION

PLEASE HOLD SERVICE UNTIL FURTHER NOTICE