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INTHE SUPERIOR COURT FOR THE STATE OF ALAS
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MATIREWNICOLA, }
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|. Emily Davenport, paintiff'in the above-captioned mater, brings his lam
‘agains the defendant based on violations of AS 18.80.220 et seq
2. Emily Davenportis a resident of Anchorage, Alaskan the Third Judicial Distt
of Alaska,
Coops
Davenport» Nicola
CaN SAN a Page tof 4Law Office of Tim Dooley
921 West Sith Avene, Seite 200
Ancoreg, Auta” 99501
ns ( 07) 258.08
Phone 907) 379.73
‘The Defendant
3. Matthew Nicolai the President of che Calista Native Corporation and has been
for many years. Tis work addres is 301 Calista Court, Suite A, Anchorage, Alaska 99518-3028
4. Mr. Nicolas residence address is 8739 Sahlee Drive, Anchorage, Alaska 99507.
5. Matthew Nicoll is a resident of Anchorage, Alaska in the Third Judicial District
‘Pactual Allegations
6, Plaintiff Emily Davenport as been employed by Calista Native Corporation since
January 2008,
7. Im August 2008, the Calista Native Corporation made Emily Devenport the
President of en advertising agency ~ “Solstice” that is wholly wned by the Calista Native
Corporation
8. Inabout September 2008, Emily Davenport and Mathew Nicoll began an
Intimate relationship with one another.
9. Inabout May 2009 Emily Davenport discontinued the relationship because ofthe
_rowing possessiveness of Matthew Nicola
10. Mr. Nicola, however, wanted to continue the relationship.
11, Mr. Nivola began earying out conduct similar to that ofa stalker.
12, The conduct inehuded following Emily when she went about Anchorage on her
personal matters, making numerous telephone calls, sending numerous e-mails tht be “loved
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‘et, and surepiousy taking pictures of her,
13. _Inaddition, Mr. Nicolai used the device of claiming that he bad received an
‘sponymous ler concerning Emily in whic the “sender” “warned” him about Ely and het
other relationships, He alo sent thee anonymous eters to fends of Emily's that claimed hat.
‘ne writer was concerned about them being involved with Emily
14, _ He continued t engage in physically touching her in an office environment in
ont of others,
15, He would discuss Emily's persona lite in font of others and, in fot of Emily,
‘Novld embarrass Enily by asking other professional women if they woul itso engage ina
threesome or if they had ever considered having srx witha woman,
16. Mr Nicoll uted his poston and influence in the Calista Native Corporation to
‘fo varios things to handicap Emily Davenpor ia het work,
17 _Forexample e hited avay akey Salsice employee that Emily had just hired, he