1 Michael Reck, State Bar No.

209895
[email protected]
2 JEFF ANDERSON & ASSOCIATES PA
12011 San Vicente Boulevard, Suite 700
3 Los Angeles, California 90049
Tel: 310-357-2425
4 Fax: 651-297-6543
5 Karen Barth Menzies, State Bar No. 180234
[email protected]
6 KBM Law Corp.
6701 Center Drive West, Suite 1400
7 Los Angeles, California, 90045
Telephone: (310) 363-0030
8 Facsimile: (310) 861-0168
9
Attorneys for Plaintiff MELISSA SCHUMAN
10

11 SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES
12
MELISSA SCHUMAN, an individual, Case No.:
13
Plaintiff, COMPLAINT FOR DAMAGES FOR:
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vs. 1) SEXUAL BATTERY
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(CIVIL CODE §1708.5);
16 NICKOLAS GENE CARTER, and DOES 1 2) SEXUAL ASSAULT;
through DOE 50, inclusive, 3) INTENTIONAL INFLICTION OF
17 EMOTIONAL DISTRESS
Defendant
18
DEMAND FOR JURY TRIAL
19
20 Plaintiff Melissa Schuman brings this action against Defendant Nickolas (Nick) Gene

21 Carter, and DOES 1 through 50, inclusive (collectively, “Defendants”), and based on information

22 and belief alleges as follows:

23 INTRODUCTION

24 Plaintiff Melissa Schuman is a survivor of sexual abuse, sexual battery, assault,

25 molestation at the hands of Defendant Nick Carter. Defendant Carter used his role, status, and

26 power as a well-known singer to gain access to, groom, manipulate, exploit, and sexually assault

27 Plaintiff Schuman in the State of California. As a result of Defendant Carter’s sexual abuse and

28 assault, Plaintiff Schuman has suffered severe emotional, physical and psychological distress,

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 1 including humiliation, shame, and guilt, economic loss, economic capacity and emotional loss.
2 Plaintiff brings this action to hold Defendant Carter accountable for the serious harm caused to
3 her.
4 JURISDICTION AND VENUE
5 1. This Court has jurisdiction over the subject matter of this action pursuant to Article
6 VI, section 10 of the California Constitution and section 410.10 of the California Code of Civil
7 Procedure.
8 2. Venue is proper in this Court under Code of Civil Procedure section 395 because a
9 substantial part of the conduct and omissions giving rise to the violations of law alleged herein
10 occurred in Los Angeles County.
11 PARTIES
12 3. Plaintiff is an adult female residing in Nevada. Plaintiff was sexually abused at age
13 18. Plaintiff brings this Complaint pursuant to California Code of Civil Procedure Section
14 340.16, as amended by Assembly Bill 2777, for the sexual assault she suffered at the hands of
15 Defendants. Thus, Plaintiff’s claims for damages suffered as a result of sexual assault are timely
16 filed as they are filed within one year of January 1, 2023.
17 4. The sexual abuse, harassment and/or assault occurred in Santa Monica, California.
18 5. Defendant Nick Carter, the perpetrator, at all times mentioned herein was and is an
19 adult male individual. In 2003, Defendant Nick Carter had been a member of the Backstreet Boys
20 for a decade and he and the singing group had become renowned and well-known. By 2003,
21 Defendant Nick Carter had acquired wealth, stature, and power as a result of his career and status
22 as an international multi-platinum recording pop star in a boy band.
23 6. On information and belief Plaintiff alleges that the true names and capacities,
24 whether individual, corporate, associate or otherwise, of Defendants named herein as Does 1
25 through 50, inclusive, are unknown to the Plaintiff, who therefore sues said Defendants by such
26 fictitious names. Plaintiff will amend the Complaint to allege their true names and capacities
27 when such have been ascertained. Upon information and belief, Defendant and each of the said
28 Doe Defendants is responsible in some manner under Code of Civil Procedure §§340.16 (e) for

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 1 the occurrences herein alleged and were a legal cause of the sexual assault and/or harassment
2 which resulted in injury to the Plaintiff as alleged herein.
3 7. At all times mentioned herein, there existed a unity of interest and ownership
4 among Defendants and each of them, such that any individuality and separateness between
5 Defendants, and each of them, ceased to exist. Defendants and each of them, were the
6 successors-in-interest and/or alter egos of the other Defendants, and each of them, in that they
7 purchased, controlled, dominated and operated each other without any separate identity,
8 observation of formalities, or other manner of division. To continue maintaining the facade of a
9 separate and individual existence between and among Defendants, and each of them, would allow
10 Defendants to perpetrate a fraud and an injustice.
11 8. At all times mentioned herein, Defendants and each of them were the agents,
12 representatives and/or employees of each and every other Defendant. In doing the things
13 hereinafter alleged, Defendants and each of them, were acting within the course and scope of said
14 alternative personality, capacity, identity, agency, representation and/or employment and were
15 within the scope of their authority, whether actual or apparent. Plaintiff is informed and believes,
16 and on that basis alleges, that at all times mentioned herein, Defendants and each of them were
17 the trustees, partners, servants, joint venturers, shareholders, contractors, and/or employees of
18 each and every other Defendant, and the acts and omissions, including a cover up or attempted
19 cover up of one or more previous instances or allegations of sexual assault or other inappropriate
20 conduct, communication or activity of a sexual nature by an alleged perpetrator of such abuse,
21 herein alleged were done by them, acting individually, through such capacity and within the
22 scope of their authority, and with the permission and consent of each and every other Defendant
23 and that said conduct was thereafter ratified by each and every other Defendant, and that each of
24 them is jointly and severally liable to Plaintiff.
25 GENERAL FACTUAL ALLEGATIONS

26 I. Defendant Nick Carter Uses His Authority and Influence to Contact Plaintiff When She
27 Was a Minor

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 1 9. Plaintiff Melissa Schuman wanted to be a singer since she was three years old and
2 she started singing in talent shows in the first grade. At age 9, she competed in Young American
3 Stars and one of the judges became her agent. Plaintiff was raised in a conservative home and
4 was not particularly interested in mainstream music or bands, she wanted to be a singer in theater
5 productions.
6 10. In middle school, Plaintiff’s vocal coach recommended she audition for a spot in
7 an all-girl singing group. Out of the hundreds of girls who tried out, only five were chosen, one
8 of whom was Plaintiff; she was age 14. The producer shopped the girl band to numerous labels.
9 After auditioning for pioneering record producer Sean “Puffy” Combs, DREAM was signed to his
10 major label, Bad Boy Records.
11 11. Plaintiff spent her high school years on the road performing throughout the United
12 States and overseas with the multi-platinum girl group DREAM. The production company
13 associated with DREAM had control of the girls’ everyday lives. They had a tutor who traveled
14 with them, and they rarely had more than a few days off at a time. DREAM became a staple of
15 MTV’s juggernaut Total Request Live (TRL) and were often referred to as “P. Diddy’s Dream
16 Team”.
17 12. In February 2001, when Plaintiff was age 16, DREAM filmed a video for their
18 song “This is Me (Remix)” featuring P. Diddy & Kain. While on set, Plaintiff’s managers told
19 her that Defendant Nick Carter, who was age 21, thought she was “cute” and that he “wanted to
20 talk to her”. Plaintiff’s management team and Defendant Carter’s team arranged for Defendant
21 Carter to call Plaintiff to speak to him on the phone during the video shoot. Plaintiff was not
22 interested in Defendant Carter romantically and told her management team that she had a
23 boyfriend. Although Plaintiff was a minor at the time, Plaintiff’s management made it clear that
24 they were in favor of Plaintiff “dating” Defendant Carter.
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II. Defendant Nick Carter Sexually Assaults Plaintiff Schuman At His Apartment In Santa
26
Monica, California
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 1 13. In the Spring of 2002, Plaintiff decided to leave DREAM and pursue her acting
2 career and she was cast in multiple TV movies, and landed her first role in a major film called
3 Love Don’t Cost a Thing.
4 14. In early 2003, Plaintiff was cast in the teen horror film The Hollow. Thereafter,
5 Defendant Carter was added to the cast of the film.
6 15. Soon after filming began, while Plaintiff was eating lunch on set with other cast
7 and crew members, Defendant Carter, who was with a male friend, invited Plaintiff to come over
8 to his apartment to hang out and play video games. Given that they each had prior work
9 experience performing in successful MTV-era pop bands, and were becoming acquaintances on
10 set, Plaintiff agreed to meet up.
11 16. Plaintiff and her roommate, who was also her childhood friend, drove to
12 Defendant’s apartment in Santa Monica. Upon arrival, Defendant Carter and his male friend
13 were about to go to the liquor store and invited the teenage women to come along.
14 17. Upon returning, Defendant Carter began making drinks and asked Plaintiff what
15 she wanted. Plaintiff told Defendant Carter that she didn’t have a lot of experience with drinking,
16 and that she didn’t know what she wanted. Defendant Carter started making drinks for everyone,
17 and he suggested Plaintiff have a drink with cranberry juice. Defendant Carter made Plaintiff a
18 drink that included at minimum a clear alcohol and cranberry juice. At this time, upon
19 information and belief, Defendant Carter put some form of flunitrazepam or a similar drug in
20 Plaintiff’s drink.
21 18. The group started to walk into the living room but then Defendant Carter asked
22 Plaintiff if she’d like to hear some of the new music he was working on. Defendant Carter took
23 Plaintiff’s hand and lead her down the hallway, past the bedroom and into his office, and sat on
24 the only chair in the room. Defendant Carter turned off the light and told Plaintiff to sit on his lap,
25 but she chose to sit on the edge of his knee. Defendant began playing music from his computer
26 and pulled Plaintiff back into him and began kissing her.
27 19. At 18 years old, Plaintiff felt self-conscious, intimidated and sexually
28 inexperienced; she had only ever kissed one other boy. Defendant Carter knew that she was a

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 1 virgin and that she held to religious, conservative Christian values. Defendant Carter took
2 Plaintiff into the bathroom and shut the door.
3 20. Defendant picked her up and put her on the bathroom counter. He started to
4 unbutton Plaintiff’s clothes. Plaintiff told him she did not want to go any further. Defendant
5 Carter responded, “Don’t worry, I won’t tell anybody.” Plaintiff continued to object. Defendant
6 Carter ignored her, and continued to assault Plaintiff, performing oral copulation upon her,
7 against her will. Plaintiff was in shock, extreme duress and started to feel as she was spinning.
8 Plaintiff turned off the light but Defendant Carter kept turning it back on, saying that he wanted to
9 look at her.
10 21. Defendant’s male friend knocked on the bathroom door and Defendant panicked
11 and quickly got Plaintiff dressed and took her out into the hallway. Plaintiff noticed that music
12 was now playing extremely loud and coming from the living room. The hallway and the
13 bedrooms were dark, with the lights turned off. Defendant Carter took Plaintiff into the other
14 bathroom that was adjacent to the bedroom and shut the door. Defendant Carter took off his
15 pants, sat on the bathroom counter and told Plaintiff to perform oral copulation on him. Plaintiff
16 refused, which made Defendant Carter very angry, and he demanded that she do it to him since he
17 did it to her. Defendant Carter forced Plaintiff to masturbate him. Plaintiff felt trapped and feared
18 that Defendant Carter would harm her physically if she didn’t comply. Plaintiff’s friend knocked
19 on the bathroom door, Defendant Carter threated Plaintiff to keep quiet by making a gesture,
20 shushing her. Plaintiff was too terrified to say anything. Defendant Carter exerted his control
21 over Plaintiff, despite knowing she did not consent, for his own sexual gratification.
22 22. Against her will, Defendant Carter took Plaintiff to the bedroom, pushed her onto a
23 twin bed and climbed on top of her. Again and again, Plaintiff said NO! She told him over and
24 over that she was a virgin, that she was saving herself for her future husband, and that she did not
25 want to have sex. Defendant Carter continued to force himself on her, whispering in her ear that
26 he could be her husband. Plaintiff could not get away from him, he was too heavy. Defendant
27 Carter forced vaginal penetration of Plaintiff. Plaintiff went limp and disassociated. After he
28 finished, Defendant got up off the bed, at which time, Plaintiff turned her body to the side and

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 1 curled into a fetal position. Plaintiff noticed Defendant Carter’s friend was laying on the floor of
2 the bedroom. Despite having a small amount of alcohol, she passed out. When the sun started
3 coming up, Plaintiff’s friend woke her up and they left. Defendant Carter was not there.
4 23. Plaintiff told her roommate and then her roommate’s mother about what Defendant
5 Carter did to her. Over the next few days, Plaintiff told her talent manager, her mother, her
6 father, her therapist, a former co-star, and others about Defendant Carter’s sexual assaults. Within
7 weeks, Plaintiff started to medicate herself repeatedly with alcohol, an issue which lasted for
8 several months until getting sober.
9 24. Defendant Carter satisfied his prurient desires, which includes the sexual assault of
10 a virgin. As a result of Defendant Carter vaginally penetrating Plaintiff, Defendant Carter
11 infected Plaintiff with the human papillomavirus (commonly known as HPV), a sexually
12 transmitted infection for which there is currently no cure. HPV is known to cause health
13 problems such as genital warts and cervical cancer. On information and belief, Defendant Carter
14 has engaged in a similar pattern of sexual abuse with other young women and minors.
15
III. Defendant Nick Carter Continues to Harass and Manipulate Plaintiff
16

17 25. Soon after assaulting Plaintiff, Defendant Carter began to manipulate and torment
18 her. Defendant Carter texted her, “Why did you make me do that.” Plaintiff’s manager highly
19 discouraged Plaintiff from going to the police to file a police report, telling her that Defendant
20 Carter has one of the most powerful litigators in the country, and that her coming forward could
21 ruin her career. Although Plaintiff still had to film scenes with Defendant, Plaintiff’s manager
22 said he would work with The Hollow production team to make sure she would otherwise not have
23 to be near Defendant Carter on set.
24 26. After the filming was finished, for weeks, Defendant Carter contacted Plaintiff by
25 phone repeatedly, demanding to speak with her. Plaintiff did not take his calls, but he would not
26 let up. On one occasion, Plaintiff finally took his call. He sounded nonchalant, until she asked
27 him about the night she was at his apartment. Defendant Carter denied having sex, exploded in
28

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 1 anger and called her a “manipulative bitch”, and yelled at her. In effort to stop the harassment,
2 Plaintiff changed her telephone number.
3 27. Plaintiff continued to pursue her acting and singing career. In late 2004 Plaintiff’s
4 agent encouraged Plaintiff to sign with a well-known and powerful manager in the music industry
5 to handle the musical side of her career. Plaintiff was aware that this manager had once worked
6 with the Backstreet Boys, but she did not know at the time that he was a close personal friend of
7 Defendant Carter.
8 28. Plaintiff signed on as a client with the music manager and began recording music
9 and taking label meetings. Soon after, her manager told her that Defendant Carter reached out and
10 specifically wanted her to record a duet with Defendant Carter, which was being pitched for a
11 movie soundtrack. Reluctant to speak negatively of Defendant in front of her new manager,
12 Plaintiff asked if she would have to record alongside Defendant Carter, and was told no, that he
13 had already pre-recorded his part of the duet. After holding up her end of this agreement, the
14 recording was never sold, and in less than a few months of working with this music manager, he
15 abruptly stopped taking her calls and stopped working with her as a client.
16 29. When Plaintiff went public with her assaults by Defendant Carter, he used this
17 song “collaboration” as “evidence” that he “was always respectful and supportive of Melissa both
18 personally and professionally.” Defendant Carter used this recording the generate the false
19 impression that he and Plaintiff had a friendly relationship.
20
IV. 2017 - Me, too: The Victim Shaming of Another Carter Survivor Compels Plaintiff to
21
Speak Publicly, For Which She Is Harassed and Attacked by Agents and Fans of
22 Defendant Carter

23 30. Plaintiff chose to speak out publicly about Defendant Carter’s sexual assault of
24 her, except for her family, friends, and co-workers with whom she talked about it over the years.
25 Then in October 2017, Plaintiff was shocked to read an exclusive article posted on
26 Radaronline.com which published a police report revealing that Defendant Carter was
27 investigated for the sexual assault of a 20-year-old female in 2006.
28

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 1 31. Infuriated and triggered by learning of another victim of Defendant with a similar
2 story, and at a time when the #MeToo social justice movement was dominating the headlines,
3 Plaintiff felt at that moment a responsibility to speak out publicly. On November 2, 2017,
4 Plaintiff made the courageous decision to post a blog on her own website a letter titled “Don’t
5 worry, I won’t tell anybody.” This blog post shared personal details of Plaintiff’s sexual assaults
6 by Defendant Carter.
7 32. On November 21, 2017, multiple television and online media outlets reported on
8 Plaintiff’s blog post. Immediately thereafter, a highly strategized cyber-stalking and harassment
9 campaign against Plaintiff unfolded through a web of individuals associated with Defendant
10 Carter.
11 33. Wonderful Union (acquired by the entertainment agency Endeavor in 2018 and
12 now called Please & Thank You) is the fan engagement company hired by Defendant Carter and
13 his band. Wonderful Union was founded by Eddie Meehan, a personal friend of Defendant Carter.
14 On information and belief, Defendant Carter utilized his Wonderful Union’s fan engagement
15 team to encourage Defendant Carter’s dedicated fan base to engage in internet intimidation in
16 effort to intimidate, blame, harass and discredit Plaintiff online.
17 34. The online intimidation by Defendant Carter’s friends, associates and/or agents is
18 an organized attempt to intimidate, blame, harass and discredit Plaintiff and her allegations of
19 sexual assault in the court of public opinion. The online intimidation stemming from Defendant
20 Carter’s sexual assault of Plaintiff has caused her further harm and is disruptive and destructive to
21 Plaintiff’s personal life, professional career and family. This online intimidation by Defendant
22 Carter’s friends, associates and/or agents is ongoing and continues to this day.
23 35. On January 1, 2023, the statute of limitations window for sexual assault claims
24 made by adult survivors opened1, which allows Plaintiff for the first time in over a decade to seek
25 adjudication of her claims for sexual assault against Defendant in a court of law. On information
26 and belief, in anticipation of this lawsuit and with the intent to intimidate and blame Plaintiff for
27 publicly exposing his sexual assault of her, Defendant Carter sued Plaintiff. Two months after
28 1
See California Code of Civil Procedure Section 340.16, as amended by Assembly Bill 2777.
9
 1 being sued for sexual assault by another survivor, Defendant Carter filed a lawsuit against
2 Plaintiff in response to the other survivor’s lawsuit, alleging a conspiracy theory that Plaintiff, her
3 father, the other survivor and Defendant Carter’s deceased brother have conspired against him to
4 extort money and gain fame.
5 FIRST CAUSE OF ACTION
6 SEXUAL BATTERY (CIVIL CODE §1708.5)
(Against Defendant Nick Carter and DOES 1 through 50)
7
36. Plaintiff re-alleges and incorporates by reference herein each and every allegation
8
contained herein above as though fully set forth and brought in this cause of action.
9
37. In 2003, Defendant Carter intentionally, recklessly and wantonly did acts which
10
were intended to, and did result in harmful and offensive contact with intimate parts of Plaintiff’s
11
person. Plaintiff was subjected to sexual assault by Defendant Carter.
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38. Defendant Carter did the aforementioned acts with the intent to cause a harmful or
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offensive contact with an intimate part of Plaintiff’s person and would offend a reasonable sense
14
of personal dignity. Further, said acts did cause a harmful or offensive contact with an intimate
15
part of Plaintiff’s person that would offend a reasonable sense of personal dignity.
16
39. Because of Defendant Carter’s position of authority over Plaintiff, and Plaintiff’s
17
mental and emotional state, Plaintiff was unable to, and did not, give meaningful consent to such
18
acts.
19
40. As a direct, legal, and proximate result of the acts of Defendant Carter, Plaintiff
20
sustained serious and permanent injuries to her person, all of which are damages in an amount to
21
be shown according to proof and within the jurisdiction of the Court.
22
41. In subjecting the Plaintiff to the wrongful treatment herein described, Defendant
23
Carter, acted willfully and maliciously with the intent to harm Plaintiff, and in conscious
24
disregard of Plaintiff’s rights, so as to constitute malice and oppression under California Civil
25
Code §3294. Plaintiff is therefore entitled to the recovery of punitive damages, in an amount to be
26
determined by the court, against Defendant Carter, in a sum to be shown according to proof.
27

28 SECOND CAUSE OF ACTION

10
 1 SEXUAL ASSAULT
(Against Defendant Nick Carter and DOES 1 through 50)
2

3 42. Plaintiff re-alleges and incorporates by reference herein each and every allegation
4 contained herein as though fully set forth and brought in this cause of action.
5 43. Defendant Carter, in doing the things herein alleged, including intending to subject
6 Plaintiff to numerous instances of sexual abuse and molestation, intended to cause harmful or
7 offensive contact with Plaintiff’s person, or intended to put Plaintiff in imminent apprehension of
8 such contact.
9 44. In doing the things herein alleged, Plaintiff was put in imminent apprehension of a
10 harmful or offensive contact by Defendant Carter, and actually believed Defendant Carter had the
11 ability to make harmful or offensive contact with Plaintiff’s person.
12 45. Plaintiff did not consent to Defendant Carter’s intended harmful or offensive
13 contact with Plaintiff’s person, or intent to put Plaintiff in imminent apprehension of such contact.
14 Additionally, because of Defendant Carter’s position of authority over Plaintiff, and Plaintiff’s
15 mental and emotional state, Plaintiff was unable to, and did not, give meaningful consent to such
16 acts.
17 46. In doing the things herein alleged, Defendant Carter violated Plaintiff’s right,
18 pursuant to Civil Code §43, of protection from bodily restraint or harm, and from personal insult.
19 In doing the things herein alleged, Defendant Carter violated his duty, pursuant to Civil Code
20 §1708, to abstain from injuring the person of Plaintiff or infringing upon Plaintiff’s rights.
21 47. As a result of the above-described conduct, Plaintiff has suffered and continues to
22 suffer great pain of mind and body, shock, emotional distress, physical manifestations of
23 emotional distress including embarrassment, loss of self-esteem, disgrace, humiliations, and loss
24 of enjoyment of life; has suffered and will continue to suffer and was prevented and will continue
25 to be prevented from performing daily activities and obtaining the full enjoyment of life; will
26 sustain loss of earnings and earning capacity, and/or has incurred and will continue to incur
27 expenses for medical and psychological treatment, therapy, and counseling.
28

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 1 48. Plaintiff is informed and based thereon alleges that the conduct of Defendant
2 Carter was oppressive, malicious and despicable in that it was intentional and done in conscious
3 disregard for the rights and safety of others, and were carried out with a conscious disregard of
4 Plaintiff’s right to be free from such tortious behavior, such as to constitute oppression, fraud or
5 malice pursuant to California Civil Code §3294, entitling Plaintiff to punitive damages against
6 Defendant Carter in an amount appropriate to punish and set an example of Defendant Carter.
7
THIRD CAUSE OF ACTION
8
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
9 (Against Defendant Carter and Does 1-50)

10 49. Plaintiff repeats, re-alleges and incorporates herein by reference all consistent
11 paragraphs of this Complaint as if fully set forth herein.
12 50. Defendant Carter intended his behavior and knew or should have known that
13 emotional distress would likely result. While Plaintiff had kept her past private, Defendant Carter
14 published information about his assaults that caused the public to identify Plaintiff.
15 51. Defendant Carter’s conduct as alleged throughout this complaint was outrageous.
16 52. Defendant Carter’s conduct exceeded all bounds of decency and is odious and
17 utterly intolerable in a civilized society.
18 53. Defendant Carter’s conduct, including sexual assault and internet intimidation,
19 caused emotional distress in Plaintiff and this emotional distress was and continues to be severe.
20 54. As a direct and proximate result of the sexual assault, internet intimidation,
21 harassment and abuse committed against the Plaintiff by Defendant Carter, Plaintiff has suffered
22 personal physical injury of sexual assault, and has and will continue to suffer, psychological,
23 mental and emotional distress, including but not limited to depression, anxiety, anger/agitation,
24 loss of appetite, trouble concentrating, feeling degraded, loss of enjoyment of life, guilt, shame,
25 humiliation, embarrassment, fear, fatigue, helplessness, loneliness, nightmares, PTSD,
26 impairment of relationships, loss of self-esteem, sleeplessness, stomach problems, stress,
27 difficulty with trust, and all associated economic injury.
28

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 1 55. As a result of the above-described conduct, Plaintiff has suffered and continues to
2 suffer emotional distress, physical manifestations of emotional distress, was prevented and will
3 continue to be prevented from performing daily activities and obtaining the full enjoyment of life,
4 and/or has incurred and and/or will continue to incur expenses for medical and psychological
5 treatment, therapy, and counseling.
6 56. These damages were all suffered as general, special and consequential damages of
7 Plaintiff, in an amount to be proven at trial, but in no event less than the minimum jurisdictional
8 amount of this Court.
9 PRAYER FOR RELIEF
10 WHEREFORE, Plaintiff requests that the Court enter a judgment against Defendants
11 awarding the following relief:
12 1) Past, present and future general damages in an amount to be determined at trial;
13 2) Past, present and future special damages, including but not limited to past, present and
14 future lost earnings, economic damages and others, in an amount to be determined at
15 trial;
16 3) Any appropriate statutory damages, including but not limited to attorneys’ fees;
17 4) Costs of suit;
18 5) Pre- and post- judgment interest as allowed by law;
19 6) Attorneys’ fees pursuant to the Code of Civil Procedure Section 1021.5, or otherwise
20 as permitted by law;
21 7) Exemplary and punitive damages in an amount to be determined at trial; and
22 8) Such other and further relief as the court may deem proper.
23
4/11/2023
24 DATED: ______________ JEFF ANDERSON & ASSOCIATES PA

25

26 ____________________________
MICHAEL RECK
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 1 KBM LAW CORP.
2

3 ____________________________
KAREN BARTH MENZIES
4
Attorneys for Plaintiff
5

6
DEMAND FOR JURY TRIAL
7 A trial by jury is hereby demanded by Plaintiff.
8
4/11/2023
DATED: ______________ JEFF ANDERSON & ASSOCIATES PA
9

10

11 ____________________________
12 MICHAEL RECK

13
KBM LAW CORP.
14

15
____________________________
16 KAREN BARTH MENZIES

17 Attorneys for Plaintiff

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