22GDCV01128

Assigned for all purposes to: Glendale Courthouse, Judicial Officer: Ralph Hofer

Electronically FILED by Superior Court of California, County of Los Angeles on 12/30/2022 11:00 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Hernandez,Deputy Clerk

1 Karen Barth Menzies, State Bar No. 180234

kbm@kbmlaw.com
2 KBM Law Corp.
6701 Center Drive West, Suite 1400
3 Los Angeles, California, 90045
Telephone: (310) 363-0030
4 Facsimile: (310) 861-0168

5
Alan Lescht and Associates, P.C.
6 1825 K Street, NW, Suite 750
Washington, DC 20006
7 Telephone: (202) 315-1736
Facsimile: (202) 463-6067
8
Attorneys for Plaintiffs, JAKARA MITCHELL
9
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA

11 FOR THE COUNTY OF LOS ANGELES

12

13

14

15 an individual; and JAKARA MITCHELL Case No.:

A.H. 2
16 COMPLAINT FOR DAMAGES FOR:

17 Plaintiffs, (1) SEXUAL BATTERY (CIVIL CODE

§1708.5) (PLAINTIFF JAKARA
18 vs. MITCHELL K.C. 1);
(2) SEXUAL ASSAULT (PLAINTIFF
19 Defendant DOE 1, an individual; Defendant DOE JAKARA MITCHELL K.C. 1);
2, an individual; Defendant DOE 3, an individual; (3) VIOLATION OF PENAL CODE §
20 and DOES 4 through DOE 50, inclusive, 647.6(a)(1) – ANNOYING AND
MOLESTING A MINOR (PLAINTIFF
21 JAKARA MITCHELL K.C. 1);
Defendants. (4) SEXUAL BATTERY (CIVIL CODE
22 §1708.5) (PLAINTIFF JAKARA
MITCHELL);
23 (5) SEXUAL ASSAULT (PLAINTIFF
JAKARA MITCHELL);
24 (6) VIOLATION
MOLESTING OFAPENAL
MINORCODE §
(PLAINTIFF
647.6(a)(1)JAKARA
– ANNOYING AND
25 MITCHELL)
Filed Pursuant to Code of Civil Procedure
26 section 340.1, as amended by Assembly Bill
218
27
DEMAND FOR JURY TRIAL
28

-1-
COMPLAINT
 1 Plaintiffs bring this action against Defendants Defendant DOE 1, DOE 2, DOE 3, and DOES 4

2 through 50, inclusive (collectively, “Defendants”), and based on information and belief alleges as

3
follows:
4
INTRODUCTION
5

6 1. Plaintiff JAKARA MITCHELL K.C. 1 and Plaintiff JAKARA MITCHELL are

7 survivors of childhood sexual abuse, sexual battery, assault, molestation, and abuse at the hands

8 of Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3.

9 2. Beginning when Plaintiff JAKARA MITCHELL K.C. 1 was a 15-year-old child and

10 Plaintiff JAKARA MITCHELL was a 13-year-old child, Defendant DOE 1 and Defendant DOE 2

11 used their role, status, and power as a well-known and successful Mexican pop star and a famous

12 producer to gain access to, groom, manipulate, and exploit them and coerce sexual contact with

13 them over a course of years, much of it occurring in the State of California. As a result of the sexual

14 harassment, abuse and assault, Plaintiffs have suffered severe emotional, physical and psychological

15 distress, including humiliation, shame, and guilt. Plaintiffs bring this action to hold Defendants

16 accountable for the serious harm they have caused them.

17 JURISDICTION AND VENUE

18 3. This Court has jurisdiction over the subject matter of this action pursuant to Article
19 VI, section 10 of the California Constitution and section 410.10 of the California Code of Civil

20 Procedure.

21 4. Venue is proper in this Court under Code of Civil Procedure section 395 because a
22 substantial part of the conduct alleged giving rise to the violations of law alleged herein occurred in

23 Los Angeles County.

24 PARTIES
25 5. Plaintiff JAKARA MITCHELL K.C. 1 is an adult female residing in Mexico.
26 Plaintiff JAKARA MITCHELL K.C. 1 was sexually abused as a minor. Plaintiff JAKARA

27 MITCHELL K.C. 1 brings this Complaint pursuant to California Code of Civil Procedure Section

28 340.1, as amended by Assembly Bill 218, for the child sexual assault she suffered at the hands of

Defendant. Thus, Plaintiff JAKARA MITCHELL K.C. 1’s claims for

-2-
COMPLAINT
 1 damages suffered as a result of childhood sexual assault are timely filed as they are filed within three

2 years of January 1, 2020. Plaintiff JAKARA MITCHELL K.C. 1 is over the age of forty (40) years

3 old. Therefore, Plaintiff JAKARA MITCHELL K.C. 1 has filed a declaration from a mental

4 healthcare practitioner, and an attorney declaration for each named defendant in this action,

5 pursuant to the requirements of Code of Civil Procedure § 340.1.

6 6. Plaintiff JAKARA MITCHELL is an adult female residing in Texas. Plaintiff

7 JAKARA MITCHELL was sexually abused as a minor. Plaintiff JAKARA MITCHELL brings this

8 Complaint pursuant to California Code of Civil Procedure Section 340.1, as amended by Assembly

9 Bill 218, for the child sexual assault she suffered at the hands of Defendant. Thus, Plaintiff
10 JAKARA MITCHELL’s claims for damages suffered as a result of childhood sexual assault are

11 timely filed as they are filed within three years of January 1, 2020. Plaintiff JAKARA MITCHELL is

12 over the age of forty (40) years old. Therefore, Plaintiff JAKARA MITCHELL has filed a

13 declaration from a mental healthcare practitioner, and an attorney declaration for each named

14 defendant in this action, pursuant to the requirements of Code of Civil Procedure § 340.1.

15 7. Defendants conduct regarding grooming, harassing and/or sexually assaulting was

16 similar as to Plaintiff JAKARA MITCHELL K.C. 1 and Plaintiff JAKARA MITCHELL, as well as

17 other young females. The childhood sexual abuse, harassment and/or assault of Plaintiff JAKARA

18 MITCHELL K.C. 1 and Plaintiff JAKARA MITCHELL occurred in Mexico and in several states

19 around the United States including California and in Los Angeles County in particular.

20 8. Defendant DOE 1, one of the alleged perpetrators, at all times mentioned herein was

21 and is an adult female individual. She was, and is, a famous and popular pop star, and one of the most

22 highly compensated female artists in Latin America. Defendant DOE 1 acquired wealth, stature, and

23 power as a result of her career. This status afforded Defendant DOE 1 particular power and influence

24 over minors including Plaintiff JAKARA MITCHELL K.C. 1 and Plaintiff JAKARA MITCHELL.

25 9. Defendant DOE 2, one of the alleged perpetrators, at all times mentioned herein was

26 and is an adult male individual. He was one of the most successful music produces in Mexico. He

27 too had acquired wealth, stature, and power as a result of his career. This status afforded Defendant

28 DOE 2 particular power and influence over minors including Plaintiff JAKARA MITCHELL K.C. 1

and Plaintiff
-3-
COMPLAINT
 1 JAKARA MITCHELL.

2 10. Defendant DOE 3, one of the alleged perpetrators, at all times mentioned herein was

3 and is an adult female individual. She was a choreographer, dancer, and assistant working for and

4 with Defendant DOE 1 and Defendant DOE 2. She benefitted from the wealth, status, and power

5 acquired by Defendant DOE 1 and Defendant DOE 2 in their career and supported their efforts to

6 acquire wealth, status and power. Defendant DOE 3’s status in Defendant DOE 1 and Defendant

7 DOE 2’s productions afforded Defendant DOE 3 particular power and influence over minors

8 including Plaintiff JAKARA MITCHELL K.C. 1 and Plaintiff JAKARA MITCHELL.

9 11. The Plaintiffs are informed and believe, and thereupon allege, that the true names and
10 capacities, whether individual, corporate, associate or otherwise, of Defendants named herein as

11 DOES 4 through 50, inclusive, are unknown to the Plaintiffs, who therefore sue said Defendants by

12 such fictitious names. Plaintiffs will amend the Complaint to allege their true names and capacities

13 when such have been ascertained. Upon information and belief, each of the said DOE Defendants is

14 responsible in some manner under Code of Civil Procedure §§ 340.1(a)(1), (2), (3), and 340.1(c) for

15 the occurrences herein alleged, and were a legal cause of the childhood sexual assault which resulted

16 in injury to the Plaintiffs as alleged herein.

17 12. Plaintiffs are informed and believe, and on that basis allege, that at all times mentioned

18 herein, there existed a unity of interest and ownership among Defendants and each of them, such that

19 any individuality and separateness between Defendants, and each of them, ceased to exist.

20 Defendants and each of them, were the successors-in-interest and/or alter egos of the other

21 Defendants, and each of them, in that they purchased, controlled, dominated and operated each other

22 without any separate identity, observation of formalities, or other manner of division. To continue

23 maintaining the facade of a separate and individual existence between and among Defendants, and

24 each of them, would allow Defendants to perpetrate a fraud and an injustice.

25 13. Plaintiffs are informed and believe, and on that basis allege, that at all times mentioned

26 herein, Defendants and each of them were the agents, representatives and/or employees of each and

27 every other Defendant. In doing the things hereinafter alleged, Defendants and each of them, were

28 acting within the course and scope of said alternative personality, capacity, identity, agency,

-4-
COMPLAINT
 1 representation and/or employment and were within the scope of their authority, whether actual or

2 apparent. Plaintiffs are informed and believe, and on that basis allege, that at all times mentioned

3 herein, Defendants and each of them were the trustees, partners, servants, joint venturers,

4 shareholders, contractors, and/or employees of each and every other Defendant, and the acts and

5 omissions herein alleged were done by them, acting individually, through such capacity and within

6 the scope of their authority, and with the permission and consent of each and every other Defendant

7 and that said conduct was thereafter ratified by each and every other Defendant, and that each of them

8 is jointly and severally liable to Plaintiffs.

9 GENERAL FACTUAL ALLEGATIONS

10 Sexual, Physical, and Emotional Abuse of Plaintiff JAKARA
11
I. Defendant DOE 1 and Defendant MITCHELL
DOE 2 entice K.C. 1
15 year-old Plaintiff JAKARA
12 MITCHELL K.C. 1 into
joining Defendant DOE 1’s popular musical act
13 14. In July and August 1991, Plaintiff JAKARA MITCHELL K.C. 1 was 15 years old.
14 15. At that time, Plaintiff JAKARA MITCHELL K.C. 1 was living in Puebla, Mexico
with her family,
15 about 100 miles outside Mexico City, Mexico.

16 16. In 1991, Defendant DOE 1 was a popular Mexican pop star and singer.
17 17. Plaintiff JAKARA MITCHELL K.C. 1 admired Defendant DOE 1, followed her
music and career
18 on television and in magazines, and dreamed of becoming a famous music star like Defendant DOE

19 1.

20 18. In or about July or August 1991, Plaintiff JAKARA MITCHELL K.C. 1’s mother
21 took Plaintiff JAKARA MITCHELL K.C. 1 and her sisters to Mexico City to attend an event at

22 which they hoped to meet Defendant DOE 1.

23 19. Plaintiff JAKARA MITCHELL K.C. 1 and her sisters joined a crowd of other
24 fans who were dancing and singing along to Defendant DOE 1’s music on the ground level of a

25 building where Defendant DOE 2, Defendant DOE 1’s music producer, had his offices.

26 20. Very soon after Plaintiff JAKARA MITCHELL K.C. 1 arrived, Defendant DOE 1
27 came out and approached her.

28 21. Defendant DOE 1 told Plaintiff JAKARA MITCHELL K.C. 1 that she had seen Plaintiff
JAKARA MITCHELL

-5-
COMPLAINT
 1 K.C. 1 dancing and that Plaintiff JAKARA MITCHELL K.C. 1 was a very good dancer and very
beautiful.
2
22. Defendant DOE 1 told Plaintiff JAKARA MITCHELL K.C. 1 that, by
3 looking for back up dancers, they
coincidence, and she invited Plaintiff JAKARA MITCHELL K.C. 1 and her family
were
4 into the offices of Defendant DOE 2.

5 23. In the office, Defendant DOE 1 introduced Plaintiff JAKARA MITCHELL K.C. 1

6 to Defendant DOE 2 for consideration as a backup dancer.

7 24. Plaintiff JAKARA MITCHELL K.C. 1 sang and danced for DOE 2 in the offices that
day.
8
25. Defendant DOE 1 and Defendant DOE 2 told Plaintiff JAKARA MITCHELL
9 mother that they would
K.C. trainher
1 and Plaintiff JAKARA MITCHELL K.C. 1 in singing and dancing so that
10 she would be able to perform as a dancer.

11 26. Plaintiff JAKARA MITCHELL K.C. 1 was told that they liked her a lot and would

12 call her to let her know if she was selected.

13 27. Plaintiff JAKARA MITCHELL K.C. 1 retuned to Puebla with her mother and

14 sisters hoping and dreaming that she would be selected as a backup dancer.

15 28. In or about November 1991, Defendant DOE 1 and Defendant DOE 3 came to Plaintiff

16 JAKARA MITCHELL K.C. 1’s family home in Puebla to tell Plaintiff 1 she had been selected.

17 29. Defendant DOE 3 was an adult female dancer, choreographer, and assistant to

18 Defendant DOE 1 and Defendant DOE 2.

19 30. At this point in 1991, Plaintiff JAKARA MITCHELL K.C. 1 had recently turned 16
years old.
20
31. Defendant DOE 1 and Defendant DOE 3 told Plaintiff JAKARA MITCHELL K.C.
21 this was a huge
1’sopportunity
mother thatfor Plaintiff JAKARA MITCHELL K.C. 1 to start a career in music
22 and television entertainment. They told Plaintiff JAKARA MITCHELL K.C. 1’s mother that she

23 would need to go with them for a “trial,” but that they should not worry about Plaintiff JAKARA

24 MITCHELL K.C. 1 because she would be with them (Defendant DOE 1 and Defendant DOE 3).

25 32. Plaintiff JAKARA MITCHELL K.C. 1’s mother knew that her daughter’s dream was

26 to become a musical artist. She agreed and entrusted Defendant DOE 1 and Defendant DOE 3

27 with the care of Plaintiff JAKARA MITCHELL K.C. 1.

28 33. Plaintiff JAKARA MITCHELL K.C. 1 was extremely excited to be selected for this
opportunity

-6-
COMPLAINT
 1 and knew it was her chance to make her dream come true.

2 34. On that day, Plaintiff JAKARA MITCHELL K.C. 1 left with Defendant DOE 1 and

3 Defendant DOE 3, to live in Mexico City with Defendant DOE 1 and be part of Defendant DOE 1’s

4 musical act.
II. Defendant DOE 1 and Defendant DOE 2 coerce and force 16-year-old Plaintiff
JAKARA MITCHELL K.C. 1 into sex with Defendant DOE 2 (sexual assault)
5
35. Beginning in or about late 1991, Plaintiff JAKARA MITCHELL K.C. 1 performed
6
in Defendant
DOE 1’s group, singing and dancing at concerts.
7
36. During the day and evening, Plaintiff JAKARA MITCHELL K.C. 1 would rehearse
8
with Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3 and the rest of the group at
9
the Mexico City locations, unless traveling or performing in other areas.
10
37. At night, Plaintiff JAKARA MITCHELL K.C. 1, Defendant DOE 1, Defendant
11
DOE 2, and the group mostly stayed in a hotel in Mexico City, the Hotel del Bosque, near Defendant
12
DOE 2’s Mexico City offices, unless they were travelling to out-of-town concerts.
13
38. At first, the living and working arrangements seemed ideal to Plaintiff JAKARA
14
MITCHELL K.C.
1. Defendants complimented her singing and dancing. Plaintiff JAKARA MITCHELL K.C. 1 now
15
realizes that the compliments were over-stated and she was not as talented as a singer as Defendants
16
claimed, but at the time, Plaintiff JAKARA MITCHELL K.C. 1 was quite young and believed
17
them and was grateful and excited to be part of the group.
18
39. Defendant DOE 1, in particular, befriended Plaintiff JAKARA MITCHELL K.C.
19
1. Defendant
DOE 1 and Plaintiff JAKARA MITCHELL K.C. 1 spent nearly all their time together and Defendant
20
DOE 1 gave Plaintiff JAKARA MITCHELL K.C. 1 advice and support, gave her constant
21
encouragement, and acted in all ways like an extremely good friend.
22
40. This idyllic environment continued for approximately 2 or 3 months. However, in late
23
1991 or early 1992, things changed.
24
41. One evening, Defendant DOE 1 came to Plaintiff JAKARA MITCHELL K.C. 1’s room at
25
the Hotel
del Bosque and told her there was a big problem. Defendant DOE 1’s demeanor was extremely grave
26
and serious – much different from her usual happy and friendly demeanor with Plaintiff JAKARA
27
MITCHELL K.C. 1.
28
42. Defendant DOE 1 told Plaintiff JAKARA MITCHELL K.C. 1 that Defendant DOE 2
discovered
-7-
COMPLAINT
 1 that Plaintiff JAKARA MITCHELL K.C. 1 had violated the rules Defendant DOE 2 set for Plaintiff
JAKARA MITCHELL
2 K.C. 1 and other females in the group. Defendant DOE 1 told Plaintiff JAKARA MITCHELL K.C.

3 1 something suggesting that Defendant DOE 2 found out that Plaintiff JAKARA MITCHELL K.C.

4 1 was friends with a male member of the group (a musician) and that Defendant DOE 2 was

5 extremely upset.

6 could have
43. anyDefendant
male friends
DOEor any
2 had
contact
strictwith
rulesmen.
that Defendant
none of theDOE
female
2 and
group
Defendant
members/dancers
DOE 1 had

7 also limited Plaintiff JAKARA MITCHELL K.C. 1’s contact/relationships with other female

8 group members. Plaintiff JAKARA MITCHELL K.C. 1’s socialization was largely restricted to

9 Defendant DOE 1 and, to a more limited degree, Defendant DOE 3.

10 44. When Defendant DOE 1 told Plaintiff JAKARA MITCHELL K.C. 1 that Defendant
DOE 2 knew
11 that Plaintiff JAKARA MITCHELL K.C. 1 was friends with a man, Defendant DOE 1 was crying and

12 told Plaintiff JAKARA MITCHELL K.C. 1 that she was so sad that Defendant DOE 2 was so upset

13 at Plaintiff JAKARA MITCHELL K.C. 1. Defendant DOE 1 told Plaintiff JAKARA MITCHELL

14 K.C. 1 that Plaintiff JAKARA MITCHELL K.C. 1 would have to leave the group unless Plaintiff

15 JAKARA MITCHELL K.C. 1 could convince Defendant DOE 2 to let her stay. Defenant DOE 1

16 stayed in Plaintiff JAKARA MITCHELL K.C. 1’s room for several hours, begging Plaintiff

17 K.C.
JAKARA
1 things
MITCHELL
like “I don’t
K.C.
want
1 you
to gotoplead
go, you
herneed
casetotogoDefendant
talk to [Defendant
DOE 2. DOE
Defendant
2], do whatever
DOE 1 told
is

18 necessary,
Plaintiff JAKARA
whateverMITCHELL
he asks of you, please just go to it, because I want you to stay. Imagine if you

19 go, you will lose this opportunity and now we are such good friends, I don’t want to miss you, I don’t

20 want to lose you.”

21 45. Plaintiff JAKARA MITCHELL K.C. 1 was devastated by this turn of events – she
did not want to
22 leave the group, to lose her new friend Defendant DOE 1, or to lose this opportunity.

23 46. Plaintiff JAKARA MITCHELL K.C. 1 finally went to Defendant DOE 2’s hotel

24 room in tears, to ask him to let her stay in the group.

25 47. Defendant DOE 2 told Plaintiff JAKARA MITCHELL K.C. 1 that if she wanted

26 to stay in the group, she had to have sexual intercourse with him.

27 48. Plaintiff JAKARA MITCHELL K.C. 1 did not want to have sex with Defendant DOE 2

28 but felt extreme pressure because she admired Defendant DOE 1 and Defendant DOE 2 (who were

adults)
-8-
COMPLAINT
 1 and she wanted to stay in the group and didn’t know what else to do. She felt she could not say no.

2 Defendant DOE 2 sexually assaulted Plaintiff JAKARA MITCHELL K.C., including coercing her

3 into sexual intercourse and other sexual acts. Plaintiff, a minor, was not capable of giving consent.

4 49. Plaintiff JAKARA MITCHELL K.C. 1 was 16 years old at the time she was first

5 sexually assaulted by Defendant DOE 2.

6 50. Defendant DOE 2 was approximately 36 years old at the time he first sexually

7 assaulted Plaintiff JAKARA MITCHELL K.C. 1.

8 51. Defendant DOE 1 was approximately 23 years at the time she first coerced, pressured,

9 and groomed Plaintiff JAKARA MITCHELL K.C. 1 to submit to being sexually assaulted by
10 Defendant
III. Defendant DOE 1 and Defendant DOE 2 continue to sexually, physically, and DOE 2.
emotionally abuse Plaintiff JAKARA MITCHELL K.C. 1
11
52. Thereafter, Defendant DOE 2 continued to sexually assault Plaintiff JAKARA
12
MITCHELL K.C.,
by pressuring and coercing Plaintiff JAKARA MITCHELL K.C. 1 into having sexual intercourse
13
with him until approximately 2001.
14
53. Defendant DOE 1 and Defendant DOE 2 also pressured, coerced and forced Plaintiff
15
JAKARA MITCHELL K.C. 1 into engaging in sexual acts with other girls in front of and with
16
Defendant DOE 2. Defendant DOE 1 often also participated in these forced sexual acts.
17
54. After successfully grooming Plaintiff JAKARA MITCHELL K.C. 1 to be abused
18
by Defendant DOE 2, Defendant DOE 1 ended her close “friendship” with Plaintiff JAKARA
19
MITCHELL K.C. 1 and, instead, began grooming other young female dancers for Defendant DOE
20
2’s sexual abuse and assaults.
21
55. Defendant DOE 1 did not come to Plaintiff JAKARA MITCHELL K.C. 1’s room or
22
hang out with her socially as much, though as the star musical performer, Defendant DOE 1 was
23
aware of and continued to facilitate Defendant DOE 2’s ongoing sexual abuse of Plaintiff JAKARA
24
MITCHELL K.C. 1.
25
56. Numerous times, Plaintiff JAKARA MITCHELL K.C. 1 went to Defendant DOE 1
26
for help57.and assistance
DefendanttoDOE
end1thewould
abusealsofrom
observe
Defendant
PlaintiffDOE
JAKARA
2, butMITCHELL
instead of offering
K.C. 1 and
support,
when
27
Defendant
DOE
Defendant
1 perceived
DOE 1 that
encouraged
PlaintiffPlaintiff
JAKARA JAKARA
MITCHELLMITCHELL
K.C. 1 was
K.C.at1 ato“breaking
continue submitting
point” fromtothe
the
28
abuse,
abuse. Defendant DOE 1 would intercede to manipulate and coerce Plaintiff JAKARA

MITCHELL K.C. 1 into staying with the -9-

COMPLAINT
 1 group, not leaving, and not telling anyone about it, causing the sexual abuse to continue.

2 58. For example, Defendant DOE 1 would tell Plaintiff JAKARA MITCHELL K.C. 1

3 that the outside world was much worse than staying with the group – Defendant DOE 1 would tell

4 Plaintiff JAKARA MITCHELL K.C. 1 that men in the outside world were more abusive and

5 women were “whores” and “bitches.” Defendant DOE 1 told Plaintiff Jane DOE K.C. 1 that

6 Plaintiff JAKARA MITCHELL K.C. 1 didn’t understand how the outside world worked because

7 she was so young. Defendant DOE 1 presented relationships like the events within the group as

8 K.C.
“normal”
1 in the
andgroup
that things
than ifwere
she much
left because
better for
thePlaintiff
outside world
JAKARA
was MITCHELL
much worse.

9 59. Defendant DOE 1 would also tell Plaintiff JAKARA MITCHELL K.C. 1 things
like, “we are a
10 family,” and “we can do this,” and “you belong here,” encouraging Plaintiff JAKARA MITCHELL

11 K.C. 1to keep submitting and cooperating.

12 60. Defendant DOE 1 also coerced Plaintiff JAKARA MITCHELL K.C. 1 into continuing

13 to submit to Defendant DOE 2 by telling Plaintiff JAKARA MITCHELL K.C. 1, “what’s waiting

14 for you if you go back to Puebla City?” and that there were no opportunities there. Defendant

15 DOE 1 would say things like, “this is your opportunity so don’t waste it. You are going to be

16 traveling, doing music, learning a lot, BUT, you need to do this” (meaning, continuing to sexually

17 satisfy Defendant DOE 2), causing Plaintiff JAKARA MITCHELL K.C. 1 to continue to be

18 sexually assaulted by Defendant DOE 2.

19 61. Additionally, when Plaintiff JAKARA MITCHELL K.C. 1 and the other

20 dancers displeased Defendant DOE 2, he would punish them with extreme physical and emotional

21 abuse.

22 62. For example, Defendant DOE 2 beat Plaintiff JAKARA MITCHELL K.C. 1 and

23 other young female dancers with electrical cords until their backs were bloody and bruised and a

24 condition of the punishment was that they could not cry out or move while he beat them – the

25 whipping did not end until they were silent and motionless as he inflicted the blows.

26 63. Defendant DOE 2 would punish Plaintiff JAKARA MITCHELL K.C. 1 for

27 imagined wrongs by forcing her to stand on her feet all day, from seven in the morning until

28 1:00 or 2:00 a.m. – approximately 18 or 19 straight hours.

64. Defendant DOE 2 would also force Plaintiff JAKARA MITCHELL K.C.
- 10–- 18 or 19 hours – so that she would be “toned”
JAKARA MITCHELL K.C. 1 to exercise all day
COMPLAINT
 1 65. Defendant DOE 1 was aware of and/or observed this physical and emotional abuse

2 and did nothing to stop it.

3 66. Plaintiff JAKARA MITCHELL K.C. 1 submitted to the continued sexual assault

4 by Defendant DOE 2 for years because of the coercion of Defendant DOE 1 and Defendant DOE 2

5 and the physical abuse by Defendant DOE 2, which was less when he was not angry or frustrated.

6 67. Although Plaintiff JAKARA MITCHELL K.C. 1 was enticed to join the group as a

7 singer and dancer, in or about late 1993, Defendant DOE 1 and Defendant DOE 2 removed Plaintiff

8 K.C. 1 from the singing and dancing and assigned her to work as an assistant.
JAKARA
They removed
MITCHELL
her

9 because they said she was not a good singer. Defendant DOE 1 and Defendant DOE 2 had only
10 pretended she was a good singer in order to promise her professional opportunities and then coerce

11 her into sexual assault by threatening to take the opportunity away. Once Plaintiff JAKARA

12 MITCHELL K.C. 1 was “broken” by on-going sexual and physical abuse, they did take away her

13 singing opportunities, but they also isolated her from her parents and made her hopeless about her

14 situation, so that she would continue to work for the group and submit to the sexual abuse and

15 assaults.

16 emotional
68.abuse
The
andtrauma
manipulation
from theby
constant
Defendant
sexual
DOEabuse
1 and
andDefendant
assaults, physical
DOE 2 caused
abuse, isolation,
Plaintiff and

17 JAKARA MITCHELL K.C. 1 to become “like a zombie,” going through the motions required to

18 survive.IV. Specific events of sexual, physical, and emotional abuse and assault in California,
when Plaintiff JAKARA MITCHELL K.C. 1 was a minor
19
69. In 1992 and 1993, Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3 took
20
Plaintiff JAKARA MITCHELL K.C. 1 and other members of the group to Los Angeles,
21
California and other California and United States locations where Defendant DOE 1 performed
22
concerts and recorded music albums.
23
70. In 1992 and until September 1993, Plaintiff JAKARA MITCHELL K.C. 1 was under
24
the age of 18 years old.
25
71. While Plaintiff JAKARA MITCHELL K.C. 1 was in California with the group in
26
1992 and 1993, Defendant DOE 2 continued sexually assault Plaintiff 1 on a regular and reoccurring
27
basis.
28
72. While Plaintiff JAKARA MITCHELL K.C. 1 was in California with the group in 1992 and

1993, Defendant DOE 2 forced and coerced-Plaintiff

11 - 1 to engage in sexual intercourse and sexual
COMPLAINT
acts with
 1 him. Plaintiff was a minor and not capable of consenting to Defedant DOE 2’s childhood sexual

2 assaults.

3 73. While Plaintiff JAKARA MITCHELL K.C. 1 was in California with the group in

4 1992 and 1993, Defendant DOE 2 forced and coerced Plaintiff JAKARA MITCHELL K.C. 1 to

5 engage in sexual acts with other girls and/or young women.

6 74. While Plaintiff JAKARA MITCHELL K.C. 1 was in California with the group in

7 1992 and 1993, Defendants coerced and forced Plaintiff JAKARA MITCHELL K.C. 1 to engage in

8 sexual intercourse and sexual acts with Defendant DOE 2 and other girls and young women because

9 he physically abused her and other girls and young women when was he was angry and/or to derive
10 pleasure from exerting control over them and hurting them.

11 75. Defendant DOE 1 was aware that Defendant DOE 2 committed childhood sexual

12 assaults on Plaintiff JAKARA MITCHELL K.C. 1 and coerced her into engaging in nonconsensual

13 sexual contact in California in 1992 and 1993.

14 76. Upon information and belief, Defendant DOE 3 was aware that Defendant DOE 2

15 committed childhood sexual assaults on Plaintiff JAKARA MITCHELL K.C. 1 and coerced her into

16 engaging in nonconsensual sexual contact in California in 1992 and 1993.

17 77. While Plaintiff JAKARA MITCHELL K.C. 1 was in California with the group in

18 1992 and 1993, Defendant DOE 2 physically abused Plaintiff JAKARA MITCHELL K.C. 1,

19 including whippings, beatings, food deprivation, and forced physical exercise.

20 78. Defendant DOE 1 was aware that Defendant DOE 2 physically abused Plaintiff

21 JAKARA MITCHELL K.C. 1, including whippings, beatings, food deprivation, and forced

22 physical exercise in California in 1992 and 1993.

23 79. Upon information and belief, Defendant DOE 3 was aware that Defendant DOE 2

24 physically abused Plaintiff JAKARA MITCHELL K.C. 1, including whippings, beatings, food

25 deprivation, and forced physical exercise in California in 1992 and 1993.

26 80. The sexual, physical, and mental abuse Plaintiff JAKARA MITCHELL K.C. 1

27 suffered took place at the hotels and homes at which Defendant DOE 1, Defendant DOE 2,

28 Defendant DOE 3, Plaintiff JAKARA MITCHELL K.C. 1, and the group stayed in Los Angeles and

other California locations.

- 12 -
COMPLAINT
 1 81. For example, on August 31, 1992, Plaintiff JAKARA MITCHELL K.C. 1 was with

2 Defendant DOE 1, Defendant DOE 2, and the group when Defendant DOE 1 performed at a

3 concert at the Roxy Theater in West Hollywood, California.

4 82. On July 7, 1993, Plaintiff JAKARA MITCHELL K.C. 1 was with Defendant DOE

5 1, Defendant DOE 2, Defendant DOE 3, and the group when Defendant DOE 1 performed at a

6 concert at the Universal Amphitheater in Los Angeles, California.

7 83. In or about the summer of 1993, Plaintiff JAKARA MITCHELL K.C. 1 was with

8 Defendant DOE 1, Defendant DOE 2, Defendant DOE 3, and the group when Defendant DOE 1

9 recorded a music album at a recording studio in or near Glendale, California.

10 84. Defendant DOE 2 produced the album, which was released in 1994.

11 85. Upon information and belief, Defendant DOE 3 participated in the production of the
12 album.

13 86. When Defendant DOE 1 performed or recorded in the Los Angeles area in 1992 and
14 1993, Plaintiff JAKARA MITCHELL K.C. 1 and the group usually stayed at the Golden Key Hotel

15 in Glendale, California, at a house on Russell Street in Glendale, California, and at a house in

16 the Los Feliz neighborhood in Los Angeles, California.

17 87. Another event Plaintiff JAKARA MITCHELL K.C. 1 attended in California was Defendant

18 DOE

19 1’s performance at Santa Ana, California’s festival, the weekend of September 18 to 20, 1992.

20 88. When Defendant DOE 1 performed at the Santa Ana festival event, the group stayed

21 at a hotel
89.in theInAnaheim
1992 and
area.
until September 1993, Plaintiff Defendant 1 was 16 and 17 years old.

22 90. Defendant DOE 2’s sexual, physical, and mental abuse of Plaintiff JAKARA
MITCHELL K.C. 1
23 described in paragraphs 71 through 79 occurred at the Best Western Golden Key Hotel and the Russell

24 Street house in Glendale, California, a house in the Los Felix neighborhood of Los Angeles,

25 California, and/or the hotel in the area of Anaheim, California in 1992 and 1993.

26 91. Plaintiff JAKARA MITCHELL K.C. 1 was never paid for any work she did for

27 Defendant DOE 1 and Defendant DOE 2 (dancing, singing, duties as an assistant, etc.). Plaintiff

28 JAKARA MITCHELL K.C. 1 had no money to escape the situation.

- 13 -
COMPLAINT
 1 92. Defendant DOE 1 and Defendant DOE 2 prohibited Plaintiff Jane DOE K.C. 1 and the

2 other young female group members from speaking to their family members without supervision.

3 93. In September 1993, Plaintiff JAKARA MITCHELL K.C. 1 turned 18 years old,

4 but nothing changed in regards to Defendant DOE 1 and Defendant DOE 2’s abuse until

5 approximately 2000, when Defendant DOE 2 was arrested and prosecuted in Mexico for sexual abuse

6 of a minor and other crimes.

7 94. Defendant DOE 1 participated in and knew of Defendant DOE 2’s sexual and physical

8 abuse of Plaintiff JAKARA MITCHELL K.C. 1 in Glendale, California and/or in the Los Angeles

9 area in 1992 and 1993.

10 95. Defendant DOE 3 participated in and knew of Defendant DOE 2’s sexual and physical

11 abuse of Plaintiff JAKARA MITCHELL K.C. 1in Glendale, California and/or in the Los Angeles area

12 in 1992 and 1993.

13 96. The grooming, sexual abuse, harassment and/or assaults were committed by Defendant

14 DOE 1 Defendant DOE 2 for their sexual gratification and was based upon the gender of the Plaintiff

15 JAKARA MITCHELL K.C. 1.

16 97. The grooming, sexual abuse, harassment and/or assaults on Plaintiff JAKARA

17 MITCHELL K.C. 1 were committed by Defendant DOE 1 and Defendant DOE 2 in Los Angeles

18 County, California and Orange County, California.

19 98. The grooming, sexually abusive, harassing and/or assaultive acts on Plaintiff

20 JAKARA MITCHELL K.C. 1 by Defendant DOE 1 and Defendant DOE 2 were committed in

21 violation of the California Penal Code, which proscribes sexual acts and misconduct against minor

22 children.

23 99. As a direct and proximate result of the childhood sexual assault, harassment and abuse

24 committed against the Plaintiff JAKARA MITCHELL K.C. 1 by Defendant DOE 1 and

25 Defendant DOE 2, Plaintiff JAKARA MITCHELL K.C. 1 has suffered personal physical injury of

26 sexual assault, and has and will continue to suffer, psychological, mental and emotional distress, and

27 all associated economic injury.

28 100. These damages were all suffered as general, special and consequential damages of

Plaintiff JAKARA MITCHELL K.C. 1, in an amount to be proven at trial, but in no event less than
- 14 -
the minimum jurisdictional amount of this Court.
COMPLAINT
 1 V. Defendant Doe 1 and Defendant Doe 2 entice 13-year-old Plaintiff JAKARA
MITCHELL 2 into attending Defendant Doe 1 and Defendant Doe 2’s “school”
2
101. In June of 1989, Plaintiff JAKARA MITCHELL was 13 years old.
3
102. She accompanied her mother to the radio station in Mexico City, Mexico where her
4
mother worked as an announcer.
5
103. Plaintiff JAKARA MITCHELL was waiting for her mother outside the radio station
6
when Defendant DOE 1 approached her and told her she was looking for girls to be singers,
7
actors, and models.
8
104. At that time, Defendant DOE 1 was an up-and-coming pop singer.
9
105. Plaintiff JAKARA MITCHELL was excited by this opportunity and gave Defendant
10
DOE
1 her phone number.
11
106. Defendant DOE 1 came to Plaintiff JAKARA MITCHELL’s house later that day and
12
said she was there on behalf of the “maestro” (Defendant DOE 2). She said Plaintiff JAKARA
13
MITCHELL had caught their attention since she was very tall and pretty.
14
107. Defendant DOE 1 told Plaintiff JAKARA MITCHELL that she and Defendant DOE
15
2 had a studio where they trained girls to be models and singers.
16
108. Defendant DOE 1 called Plaintiff JAKARA MITCHELL two weeks later and invited
17
her to audition.
18
109. Plaintiff JAKARA MITCHELL and her mother went to the audition where Defendant
19
DOE 1 introduced her to Defendant DOE 2, a very successful and well-known music producer.
20
110. For the audition, Plaintiff JAKARA MITCHELL was first asked to sing and dance,
21
which she did.
22
111. Eventually Defendant DOE 1 told Plaintiff JAKARA MITCHELL that for the next
23
part of the audition she would need to be nude. Defendant DOE 1 took Plaintiff JAKARA
24
MITCHELL to a private room to disrobe.
25
112. Plaintiff JAKARA MITCHELL was reluctant to take her clothes off. Defendant DOE
26
1 told Plaintiff JAKARA MITCHELL that the nude portion of the audition was very important.
27
Defendant DOE 1 reassured Plaintiff JAKARA MITCHELL that it was ok, and that she had done
28
it for her own original audition. Defendant DOE 1 went on to explain that the nudity was

necessary because Defendant - 15 -

COMPLAINT
 1 DOE 2 had to see what parts of her body needed work.

2 113. Plaintiff JAKARA MITCHELL did not agree to appear nude.

3 114. Defendant DOE 1 told Plaintiff JAKARA MITCHELL that she understood, and
that she
4 could return when ready. She told Plaintiff JAKARA MITCHELL “It will happen at some point

5 if you want to move forward.”

6 115. Defendant DOE 1 spoke to Plaintiff JAKARA MITCHELL’s mother and told her

7 that Plaintiff JAKARA MITCHELL had a great audition, that Plaintiff JAKARA MITCHELL was

8 very talented, that she would likely get a scholarship to Defendant DOE 2’s school for girls, and

9 that she (the mother) would be involved in Plaintiff JAKARA MITCHELL’s development.
10 116. Defendant DOE 1 told Plaintiff JAKARA MITCHELL that she was perfect for the

11 academy because she was tall and pretty.

12 117. Plaintiff JAKARA MITCHELL was given a scholarship and she started attending

13 classes at the same house where she had auditioned. She attended classes on music, dancing, and

14 acting which were taught by Defendant DOE 2.

15 118. Whenever there was free time at the school, Defendant DOE 1 would talk to and

16 befriend Plaintiff JAKARA MITCHELL.

17 119. Defendant DOE 1’s acts to befriend Plaintiff JAKARA MITCHELL were to groom

18 Plaintiff JAKARA MITCHELL to perform sexual acts with Defendant DOE 2.

19 120. For example, Defendant DOE 1 would tell Plaintiff JAKARA MITCHELL about

20 how amazing Defendant DOE 2 was, how talented her was, and how she (Defendant DOE 1) was in

21 love with him, but that Defendant DOE 2 only saw Defendant DOE 1 as friend and didn’t see her

22 as a girlfriend.

23 121. Defendant DOE 1 told Plaintiff JAKARA MITCHELL that she (Plaintiff JAKARA
MITCHELL A.H.
24 2) could be Defendant DOE 2’s girlfriend.

25 122. Defendant DOE 1 would also tell Plaintiff JAKARA MITCHELL that she
(Plaintiff Jane
26 DOE A.H. 2) could be the girl that would make Defendant DOE 2 fall in love and make him believe

27 in love again. Defendant DOE 1 said that Defendant DOE 2 had suffered a lot because of a girl

28 with whom he had been in love and “betrayed him,” who was Plaintiff JAKARA MITCHELL’s age.

- 16 -
COMPLAINT
 1 123. In 1989 and early 1990, Plaintiff JAKARA MITCHELL was 13 and 14 years

2 old respectively.

3 124. At the same time, Defendant DOE 1 was approximately 21 years old.

4 125. At the same time, Defendant DOE 2 was approximately 33 years old.

5 126. In or about late summer 1989, before Plaintiff JAKARA MITCHELL A.H. 2 turned
fourteen years
6 old, Defendant DOE 2 began sexually assaulting Plaintiff JAKARA MITCHELL A.H. 2, including

7 coercing sexual intercourse with her in an apartment in Mexico City and in the office where the

8 lessons were held.

9 127. Defendant DOE 2 began treating Plaintiff Jane DOE A.H. 2 very nicely, treating her
10 like she was his girlfriend and told her that sexual relations were a normal part of that relationship.

11 Plaintiff Jane DOE A.H. 2, still only 13 years old, submitted to his sexual advances though she did

12 not want to. Plaintiff Jane DOE A.H. 2 was a minor and not capable of consenting. She often tried to

13 avoid situations where she would be alone with him or where he would have an opportunity to her.

14 128. After Defendant DOE 2 started sexually assaulting Plaintiff Jane DOE A.H. 2, his

15 demeanor towards her and the way he treated her started to change. He became increasingly

16 controlling and prohibited her from socializing with family and friends.

17 129. Defendant DOE 2 also became emotionally abusive and manipulative to keep Plaintiff

18 Jane DOE A.H. 2 under his control. For example, he promised to help Plaintiff Jane DOE A.H. 2

19 record her own album and make her a star like Defendant DOE 1. He had a calendar on his office

20 wall on which he would write the date when he would take Plaintiff Jane DOE A.H. 2 to Los Angeles,

21 California to record an album of her singing. If Plaintiff Jane DOE A.H. 2 resisted his demands or

22 “misbehaved,” he would cross out the date and tell her that he would not take her to record her album

23 unless she was good, and that the delay was her own fault.

24 130. After Defendant DOE 2 began having intercourse with Plaintiff Jane DOE A.H. 2,

25 Defendant DOE 1 withdrew from the friendship with Plaintiff Jane DOE A.H. 2 – she no longer

26 chatted VI.
withDefendant
her or actedDOE
like 1a friend. It was if DOE
and Defendant Defendant DOEPlaintiff
2 deceive 1’s job was
Janedone.
DOE A.H. 2’s
parents and take her to California
27
131. In August or September of 1990, Defendant DOE 1 and Defendant DOE 2 went to
28
Plaintiff Jane DOE A.H. 2’s house to obtain her passport and visa in order to bring Plaintiff Jane DOE

- 17 -
COMPLAINT
 1 A.H. 2 to California.

2 132. At this time, Plaintiff Jane DOE A.H. 2 was approximately 14 years old.

3 133. That day, Plaintiff Jane DOE A.H. 2’s mother was out of town on a business trip.

4 134. Defendant DOE 1 and Defendant DOE 2 told Plaintiff Jane DOE A.H. 2’s stepfather

5 that her mother had authorized them to get Plaintiff Jane DOE A.H. 2’s travel documents. This was

6 false.

7 135. Defendant DOE 1 and Defendant DOE 2 did not obtain permission from Plaintiff Jane

8 DOE A.H. 2’s mother to get her passport or take her travelling anywhere, much less the United States.

9 136. However, Defendant DOE 2 did take Plaintiff Jane DOE A.H. 2 to Los Angeles,
10 California.

11 137. First Defendant DOE 2 took Plaintiff Jane DOE A.H. 2 to Los Angeles for a day trip.
12 In retrospect, this same-day round trip might have been a test to see how everyone would react.

13 138. Then, from 1990 through 1992, Defendant DOE 2 and Defendant DOE 1 took Plaintiff
14 Jane DOE A.H. 2 to Los Angeles to stay for longer periods of time (weeks and months).

15 139. When staying in the Los Angeles area and other California locations, the abuse
16 continued, including the childhood sexual assaults.

17 140. In Los Angeles, like in Mexico, Defendant DOE 2 and Defendant DOE 1 controlled
18 every aspect of Plaintiff Jane DOE A.H. 2’s life.

19 141. Defendant DOE 1 and Defendant DOE 2 did not pay Plaintiff Jane DOE A.H. 2 any
20 wages for her work, nor did they give her any other money.

21 142. Defendant DOE 1 and Defendant DOE 2 provided lodging and controlled when and
22 where Plaintiff Jane DOE A.H. 2 slept, when and what she ate, when she was permitted to go to the

23 bathroom, and with whom she was permitted to associate (which was no one except Defendant DOE

24 2 and the other females in his group, including Plaintiff Jane DOE K.C. 1, and almost always under

25 supervision of Defendant DOE 2, Defendant DOE 1, and/or Defendant DOE 3).

26 143. If Plaintiff Jane DOE A.H. 2 did not comply with Defendant DOE 2’s demands, or
27 showed resistance, he would beat her with a belt, punch her, slap her, deprive her of food, and prohibit

28 her from using the bathroom.

- 18 -
COMPLAINT
 1 144. Plaintiff Jane DOE A.H. 2 could hear Defendant DOE 2 viscously beating other young

2 females in the group in his California hotel rooms and offices.

3 145. Plaintiff Jane DOE A.H. 2 could also hear Defendant DOE 2 engaging in childhood

4 sexual assaults with other females she knew to be underage, in his California offices and hotel rooms.

5 146. In the Los Angeles area, like in Mexico, DOE 2 continued to sexually assault Plaintiff

6 Jane DOE A.H. 2 and physically abuse her.

7 VII. Defendant DOE 2 prevents Plaintiff Jane DOE A.H. 2’s mother from regaining custody
and marries 15 year-old Plaintiff Jane DOE A.H. 2
8
147. In or about the fall of 1990, Plaintiff Jane DOE A.H. 2’s mother came to the U.S. to
9
retrieve her from Defendant DOE 1 and Defendant DOE 2’s control. She confronted them at the
10
studio Milagro Sound and in the Hotel Golden Key (Best Western) in Glendale, California.
11
148. After repeated attempts but being diverted and blocked from regaining custody of her
12
daughter, Plaintiff Jane DOE A.H. 2’s mother had to return to Mexico without Plaintiff Jane DOE
13
A.H. 2.
14
149. Shortly thereafter, Plaintiff Jane DOE A.H. 2 was able to avoid Defendant DOE 1,
15
Defendant DOE 2, and Defendant DOE 3’s supervision long enough to call her mother and ask her
16
to please come get her and take her away from these “bad people.”
17
150. Plaintiff Jane DOE A.H. 2’s mother returned to the U.S.
18
151. Plaintiff Jane DOE A.H. 2 wanted to leave DOE 1 and DOE 2 and go back to Mexico
19
with her mother.
20
152. However, then Defendant DOE 2 spoke to Plaintiff Jane DOE A.H. 2 privately, outside
21
the presence of her mother. Defendant DOE 2 was extremely upset that Plaintiff Jane DOE A.H. 2’s
22
mother was there and told Plaintiff Jane DOE A.H. 2 that she had to make her mother leave. Plaintiff
23
Jane DOE A.H. 2 was terrified of Defendant DOE 2.
24
153. Defendant DOE 1 and Defendant DOE 3 spent hours talking to Plaintiff Jane DOE
25
A.H. 2, encouraging her to stay, and telling her that she was so close to completing her album and
26
reaching her dream of becoming a singer.
27
154. Finally, Plaintiff Jane DOE A.H. 2 felt broken down and scared that she felt she had
28
no choice but to stay – she told her mother that she was not leaving because they were almost done

- 19 -
COMPLAINT
 1 recording her album and that she would be back in Mexico in a few days.

2 155. Therefore, her mother again left California without her and the childhood sexual

3 assaults continued.

4 156. When Plaintiff Jane DOE A.H. 2 returned to Mexico City with the group, her mother

5 tried to keep her from remaining with Defendant DOE 2.

6 157. However, Plaintiff Jane DOE A.H. 2 was terrified that if she did not continue a

7 relationship with Defendant DOE 2, he would inflict severe punishment and beatings on her, and

8 potentially kill her.

9 158. On or about December 1, 1990, Defendant DOE 2 married Plaintiff Jane DOE A.H. 2
10 in México City. She was 15 years old.

11 159. Defendant DOE 2 married Plaintiff Jane DOE A.H. 2 in order to remove her from her
12 mother’s legal custody and so that he would be able to legally travel with Plaintiff Jane DOE A.H. 2.

13 160. Plaintiff Jane DOE A.H. 2 went through with the marriage because she was terrified
14 of what Defendant DOE 2 would do if she refused.

15 161. After Defendant DOE 2 married Plaintiff Jane DOE A.H. 2, his abuse and control of
16 her became even worse.

17 VIII. Specific events of sexual abuse in California, when Plaintiff Jane DOE A.H. 2 was
a minor
18
162. After Defendant DOE 2 married Plaintiff Jane DOE A.H. 2, he took her back to the
19
Los Angeles, California area for weeks and months at a time in 1991 and 1992.
20
163. For example, Plaintiff Jane DOE A.H. 2 and Defendant DOE 2 lived at the Golden
21
Key Hotel and/or a nearby apartment near the studio Milagro Sound in Glendale, California in 1991
22
and 1992.
23
164. Specific occasions when Defendant DOE 2 sexually assaulted Plaintiff Jane DOE A.H.
24
2 in the Los Angeles, California area was in late summer/fall 1990, when Defendant DOE 2 was
25
recording Plaintiff Jane DOE A.H. 2’s album, and in 1991 and 1992 when Defendant DOE 1 and
26
Defendant DOE 2 were in the Los Angeles area to record Defendant DOE 1’s albums Tua Ángel de
27
la Guarda (released in 1991) and Mi Siento Tan Sola (released in 1992).
28
165. On numerous dates from approximately August 1990 through 1992, Defendant DOE

- 20 -
COMPLAINT
 1 2 committed childhood multiple sexual assaults on Plaintiff Jane DOE A.H. 2 at the Golden Key

2 Hotel in Glendale, California and other locations in the Los Angeles, California area when she was

3 less than 18 years of age.

4 166. On numerous dates from approximately August 1990 through December 1992,

5 Defendant DOE 2 forced and coerced Plaintiff Jane DOE A.H. 2 to engage in sexual acts with him at

6 the Golden Key Hotel in Glendale, California and other locations in the Los Angeles area when she

7 was less than 18 years of age.

8 167. Defendant DOE 1 participated in and knew of Defendant DOE 2’s childhood sexual

9 assaults and physical abuse of Plaintiff Jane DOE A.H. 2 in Glendale, California and/or in the Los
10 Angeles area in 1990 through 1992.

11 168. Defendant DOE 3 participated in and knew of Defendant DOE 2’s childhood sexual
12 assaults and physical abuse of Plaintiff Jane DOE A.H. 2 in Glendale, California and/or in the Los

13 Angeles area in 1990 through 1992.

14 169. Finally, in December of 1992, Plaintiff Jane DOE A.H. 2 escaped from the group home
15 in Mexico City.

16 170. The grooming, harassment and/or childhood sexual assaults were committed by
17 Defendant DOE 1 and Defendant DOE 2 for their sexual gratification and was based upon the gender

18 of the Plaintiff Jane DOE A.H. 2.

19 171. The grooming, sexual abuse, harassment and/or assaults were committed by Defendant
20 DOE 1 and Defendant DOE 2 in Los Angeles County, California.

21 172. The grooming, harassing and/or childhood sexual assaultive acts by Defendant DOE
22 1 and Defendant DOE 2 were committed in violation of the California Penal Code, which proscribes

23 sexual acts and misconduct against minor children.

24 173. As a direct and proximate result of the childhood sexual assault, harassment and abuse
25 committed against the Plaintiff Jane DOE A.H. 2 by Defendant DOE 1 and Defendant DOE 2,

26 Plaintiff Jane DOE A.H. 2 has suffered the personal physical injury of sexual assault, and has and

27 will continue to suffer, psychological, mental and emotional distress, and all associated economic

28 injury.

- 21 -
COMPLAINT
 1 174. These damages were all suffered as general, special, and consequential damages of

2 Plaintiff Jane DOE A.H. 2, in an amount to be proven at trial, but in no event less than the minimum

3 jurisdictional amount of this Court.

4 FIRST CAUSE OF ACTION

SEXUAL BATTERY (CIVIL CODE § 1708.5)
5 (By Plaintiff Jane DOE K.C. 1 against Defendant DOES 1 through 50)
6

7 175. Plaintiff Jane DOE K.C. 1 re-alleges and incorporates by reference herein each and

8 every allegation contained herein above as though fully set forth and brought in this cause of action.

9 176. In 1991 through 2000, DOES 1 – 50, intentionally, recklessly and wantonly did acts

10 which were intended to, and did result in harmful and offensive contact with intimate parts of Plaintiff

11 Jane DOE K.C. 1’s person. Plaintiff Jane DOE K.C. 1 was subjected to at least one instance of sexual

12 assault by Defendant DOE 1 and Defendant DOE 2, during Plaintiff Jane DOE K.C. 1’s time as a

13 minor (through dates in September 1992).

14 177. Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3 did the aforementioned

15 acts with the intent to cause a harmful or offensive contact with an intimate part of Plaintiff Jane DOE

16 K.C. 1’s person and would offend a reasonable sense of personal dignity. Further, said acts did cause

17 a harmful or offensive contact with an intimate part of Plaintiff Jane DOE K.C. 1’s person that would

18 offend a reasonable sense of personal dignity.

19 178. Because of Defendant DOE 1 and Defendant DOE 2’s position of authority over

20 Plaintiff Jane DOE K.C. 1, and Plaintiff Jane DOE K.C. 1’s mental and emotional state, and Plaintiff

21 Jane DOE K.C. 1’s young age which was under the age of consent, Plaintiff Jane DOE K.C. 1 was

22 unable to, and did not, give meaningful consent to such acts.

23 179. The aforementioned acts constituted criminal sexual conduct pursuant to the California

24 Penal Code.

25 SECOND CAUSE OF ACTION

SEXUAL ASSAULT
26 (By Plaintiff Jane DOE K.C. 1 against Defendant DOES 1 through 50)
27 180. Plaintiff 1 re-alleges and incorporates by reference herein each and every allegation
28 contained herein as though fully set forth and brought in this cause of action.

- 22 -
COMPLAINT
 1 181. Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3, in doing the things herein

2 alleged, including intending to subject Plaintiff Jane DOE K.C. 1 to numerous instances of sexual

3 abuse and molestation, intended to cause harmful or offensive contact with Plaintiff Jane DOE K.C.

4 1’s person, or intended to put Plaintiff 1 in imminent apprehension of such contact.

5 182. In doing the things herein alleged, Plaintiff Jane DOE K.C. 1 was put in imminent

6 apprehension of a harmful or offensive contact by Defendant DOE 1 and Defendant DOE 2, and

7 actually believed Defendant DOE 1 and Defendant DOE 2 had the ability to make harmful or

8 offensive contact with Plaintiff Jane DOE K.C. 1’s person.

9 183. Plaintiff Jane DOE K.C. 1 did not consent to Defendant DOE 1 and Defendant DOE
10 2’s intended harmful or offensive contact with Plaintiff Jane DOE K.C. 1’s person, or intent to put

11 Plaintiff Jane DOE K.C. 1 in imminent apprehension of such contact. Additionally, because Plaintiff

12 Jane DOE K.C. 1 was a minor during the time herein alleged, she lacked the ability to consent to

13 sexual contact with any person.

14 184. In doing the things herein alleged, Defendant DOE 1, Defendant DOE 2, and
15 Defendant DOE 3 violated Plaintiff 1’s right, pursuant to Civil Code § 43, of protection from bodily

16 restraint or harm, and from personal insult. In doing the things herein alleged, Defendant DOE 1 and

17 Defendant DOE 2 violated their duty, pursuant to Civil Code § 1708, to abstain from injuring the

18 person of Plaintiff Jane DOE K.C. 1 or infringing upon Plaintiff Jane DOE K.C. 1’s rights.

19 185. As a result of the above-described conduct, Plaintiff Jane DOE K.C. 1 has suffered
20 and continues to suffer great pain of mind and body, shock, emotional distress, physical

21 manifestations of emotional distress including embarrassment, loss of self-esteem, disgrace,

22 humiliations, and loss of enjoyment of life; has suffered and will continue to suffer and was prevented

23 and will continue to be prevented from performing daily activities and obtaining the full enjoyment

24 of life; will sustain loss of earnings and earning capacity, and/or has incurred and will continue to

25 incur expenses for medical and psychological treatment, therapy, and counseling.

26 186. Plaintiff Jane DOE K.C. 1 is informed and based thereon alleges that the conduct of
27 Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3 was oppressive, malicious and

28 despicable in that it was intentional and done in conscious disregard for the rights and safety of others,

- 23 -
COMPLAINT
 1 and were carried out with a conscious disregard of Plaintiff Jane DOE K.C. 1’s right to be free from

2 such tortious behavior, such as to constitute oppression, fraud or malice pursuant to California Civil

3 Code § 3294, entitling Plaintiff 1 to punitive damages against Defendant DOE 1 and Defendant DOE

4 2 in an amount appropriate to punish and set an example of Defendant DOE 1, Defendant DOE 2,

5 and Defendant DOE 3.

6 THIRD CAUSE OF ACTION

VIOLATION OF PENAL CODE § 647.6(a)(1) –
7 ANNOYING OR MOLESTING A MINOR
(Plaintiff Jane DOE K.C. 1 against Defendants DOES 1 and 2 only)
8

9 187. Plaintiff Jane DOE K.C. 1 re-alleges and incorporates by reference herein each and

10 every allegation contained herein as though fully set forth and brought in this cause of action.

11 188. California Penal Code § 647.6(a)(1) provides that “[e]very person who annoys or

12 molests any child under 18 years of age shall be punished by a fine not exceeding five thousand

13 dollars ($5,000), by imprisonment in a county jail not exceeding one year, or by both the fine and

14 imprisonment.”

15 189. Defendant DOE 1 and Defendant DOE 2 sexually molested and annoyed Plaintiff Jane

16 DOE K.C. 1 while Plaintiff Jane DOE K.C. 1 was under eighteen (18) years of age, in violation of

17 California Penal Code § 647.6(a)(1).

18 190. Under California law, victims of childhood sexual abuse are entitled to bring civil

19 actions for violations of Penal Code provisions that prohibit adults from engaging in sexual acts with

20 minors, including Penal Code § 647.6(a)(1). See Angie M. v. Superior Court (Hiemstra) 37 Cal. App.

21 4th 1217, 1224-25 (1995).

22 191. Defendant DOE 1 and Defendant DOE 2’s above-noted actions in annoying and

23 molesting minor Plaintiff Jane DOE K.C. 1 were the proximate and legal causes of physical,

24 psychological, emotional, and economic damages which Plaintiff Jane DOE K.C. 1 has suffered and

25 continues to suffer to this day. It also has resulted in Plaintiff Jane DOE K.C. 1 incurring and will

26 require Plaintiff Jane DOE K.C. 1 to incur into the future, expenses for medical and psychological

27 treatment, therapy, and counseling.

28 192. The above-described conduct of Defendant DOE 1 and Defendant DOE 2 was

oppressive, malicious and despicable in that it was intentional and done in conscious disregard for the

- 24 -
COMPLAINT
 1 rights and safety of Plaintiff Jane DOE K.C. 1, and was carried out with a conscious disregard of

2 Plaintiff Jane DOE K.C. 1’s right to be free from such tortious behavior, such as to constitute

3 oppression, fraud or malice pursuant to California Civil Code § 3294, entitling Plaintiff Jane DOE

4 K.C. 1 to punitive damages against Defendant DOE 1 and Defendant DOE 2 in an amount appropriate

5 to punish and set an example of Defendant DOE 1 and Defendant DOE 2.

6 FOURTH CAUSE OF ACTION

SEXUAL BATTERY (CIVIL CODE § 1708.5)
7 (By Plaintiff Jane DOE A.H. 2 against Defendant DOES 1 through 50)
8
193. Plaintiff Jane DOE A.H. 2 re-alleges and incorporates by reference herein each and
9
every allegation contained herein above as though fully set forth and brought in this cause of action.
10
194. In 1990 through 1992, DOES 1 – 50, intentionally, recklessly and wantonly did acts
11
which were intended to, and did result in harmful and offensive contact with intimate parts of Plaintiff
12
Jane DOE A.H. 2’s person. Plaintiff Jane DOE A.H. 2 was subjected to at least one instance of sexual
13
assault by Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3 during Plaintiff Jane DOE
14
A.H. 2’s time as a minor.
15
195. Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3 did the aforementioned
16
acts with the intent to cause a harmful or offensive contact with an intimate part of Plaintiff Jane DOE
17
A.H. 2’s person and would offend a reasonable sense of personal dignity. Further, said acts did cause
18
a harmful or offensive contact with an intimate part of Plaintiff Jane DOE A.H. 2’s person that would
19
offend a reasonable sense of personal dignity.
20
196. Because of Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3’s positions
21
of authority over Plaintiff Jane DOE A.H. 2, and Plaintiff Jane DOE A.H. 2’s mental and emotional
22
state, and Plaintiff Jane DOE A.H. 2’s young age which was under the age of consent, Plaintiff Jane
23
DOE A.H. 2 was unable to, and did not, give meaningful consent to such acts.
24
197. The aforementioned acts constituted criminal sexual conduct pursuant to the California
25
Penal Code.
26
FIFTH CAUSE OF ACTION
27 SEXUAL ASSAULT
(By Plaintiff Jane DOE A.H. 2 against Defendant DOES 1 through 50)
28
198. Plaintiff Jane DOE A.H. 2 re-alleges and incorporates by reference herein each and

- 25 -
COMPLAINT
 1 every allegation contained herein as though fully set forth and brought in this cause of action.

2 199. Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3, in doing the things herein

3 alleged, including intending to subject Plaintiff Jane DOE A.H. 2 to numerous instances of sexual

4 abuse and molestation, intended to cause harmful or offensive contact with Plaintiff Jane DOE A.H.

5 2’s person, or intended to put Plaintiff Jane DOE A.H. 2 in imminent apprehension of such contact.

6 200. In doing the things herein alleged, Plaintiff Jane DOE A.H. 2 was put in imminent

7 apprehension of a harmful or offensive contact by Defendant DOE 2 and actually believed Defenant

8 DOE 2 had the ability to make harmful or offensive contact with Plaintiff Jane DOE A.H. 2’s person.

9 201. Plaintiff Jane DOE A.H. 2 did not consent to Defendant DOE 1, Defendant DOE 2
10 and Defendant DOE 3’s intended harmful or offensive contact with Plaintiff Jane DOE A.H. 2’s

11 person, or intent to put Plaintiff Jane DOE A.H. 2 in imminent apprehension of such contact.

12 Additionally, because Plaintiff Jane DOE A.H. 2 was a minor during the time herein alleged, she

13 lacked the ability to consent to sexual contact with any person.

14 202. In doing the things herein alleged, Defendant DOE 1, Defendant DOE 2, and
15 Defendant DOE 3 violated Plaintiff Jane DOE A.H. 2’s right, pursuant to Civil Code § 43, of

16 protection from bodily restraint or harm, and from personal insult. In doing the things herein alleged,

17 Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3 violated their duty, pursuant to Civil

18 Code § 1708, to abstain from injuring the person of Plaintiff Jane DOE A.H. 2 or infringing upon

19 Plaintiff Jane DOE A.H. 2’s rights.

20 203. As a result of the above-described conduct, Plaintiff Jane DOE A.H. 2 has suffered
21 and continues to suffer great pain of mind and body, shock, emotional distress, physical

22 manifestations of emotional distress including embarrassment, loss of self-esteem, disgrace,

23 humiliations, and loss of enjoyment of life; has suffered and will continue to suffer and was prevented

24 and will continue to be prevented from performing daily activities and obtaining the full enjoyment

25 of life; will sustain loss of earnings and earning capacity, and/or has incurred and will continue to

26 incur expenses for medical and psychological treatment, therapy, and counseling.

27 204. Plaintiff Jane DOE A.H. 2 is informed and based thereon alleges that the conduct of
28 Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3 was oppressive, malicious and

- 26 -
COMPLAINT
 1 despicable in that it was intentional and done in conscious disregard for the rights and safety of others,

2 and were carried out with a conscious disregard of Plaintiff Jane DOE A.H. 2’s right to be free from

3 such tortious behavior, such as to constitute oppression, fraud or malice pursuant to California Civil

4 Code § 3294, entitling Plaintiff Jane DOE A.H. 2 to punitive damages against Defendant DOE 1,

5 Defendant DOE 2, and Defendant DOE 3 in an amount appropriate to punish and set an example of

6 Defendant DOE 1, Defendant DOE 2, and Defendant DOE 3.

7 SIXTH CAUSE OF ACTION

VIOLATION OF PENAL CODE § 647.6(a)(1) –
8 ANNOYING OR MOLESTING A MINOR
(Plaintiff 2 against DEFENDANT DOE 2 only)
9
10 205. Plaintiff Jane DOE A.H. 2 re-alleges and incorporates by reference herein each and

11 every allegation contained herein as though fully set forth and brought in this cause of action.

12 206. California Penal Code § 647.6(a)(1) provides that “[e]very person who annoys or

13 molests any child under 18 years of age shall be punished by a fine not exceeding five thousand

14 dollars ($5,000), by imprisonment in a county jail not exceeding one year, or by both the fine and

15 imprisonment.”

16 207. Defendant DOE 2 sexually molested and annoyed Plaintiff Jane DOE A.H. 2 while

17 Plaintiff Jane DOE A.H. 2 was under eighteen (18) years of age, in violation of California Penal Code

18 § 647.6(a)(1).

19 208. Under California law, victims of childhood sexual abuse are entitled to bring civil

20 actions for violations of Penal Code provisions that prohibit adults from engaging in sexual acts with

21 minors, including Penal Code § 647.6(a)(1). See Angie M. v. Superior Court (Hiemstra) 37 Cal. App.

22 4th 1217, 1224-25 (1995).

23 209. Defendant DOE 2’s above-noted actions in annoying and molesting minor Plaintiff

24 Jane DOE A.H. 2 were the proximate and legal causes of physical, psychological, emotional, and

25 economic damages which Plaintiff Jane DOE A.H. 2 has suffered and continues to suffer to this day.

26 It also has resulted in Plaintiff Jane DOE A.H. 2 incurring and will require Plaintiff Jane DOE A.H.

27 2 to incur into the future, expenses for medical and psychological treatment, therapy, and counseling.

28 210. The above-described conduct of Defendant DOE 2 was oppressive, malicious and

despicable in that it was intentional and done in conscious disregard for the rights and safety of

- 27 -
COMPLAINT
 1 Plaintiff 1, and was carried out with a conscious disregard of Plaintiff Jane DOE A.H. 2’s right to be

2 free from such tortious behavior, such as to constitute oppression, fraud or malice pursuant to

3 California Civil Code § 3294, entitling Plaintiff Jane DOE A.H. 2 to punitive damages against

4 Defendant DOE 1 and Defendant DOE 2 in an amount appropriate to punish and set an example of

5 Defendant DOE 1 and Defendant DOE 2.

6 DAMAGES

7 211. As a direct, legal, and proximate result of the acts of Defendant DOE 1 and Defendant
8 DOE 2, Plaintiff Jane DOE K.C. 1 and Plaintiff Jane DOE A.H. 2 sustained serious and permanent

9 injuries to their persons, all of which are damages in an amount to be shown according to proof and
10 within the jurisdiction of the Court.

11 212. As a direct result of the sexual battery by Defendant DOE 1 and Defendant DOE 2,
12 Plaintiff Jane DOE K.C. 1 and Plaintiff Jane DOE A.H. 2 have had difficulty in reasonably or

13 meaningfully interacting with others, including those in positions of authority including supervisors,

14 and in intimate, confidential and familial relationships, due to the trauma of childhood sexual assault

15 inflicted upon Plaintiff Jane DOE K.C. 1 and Plaintiff Jane DOE A.H. 2 by Defendants. This inability

16 to interact creates conflict with Plaintiff Jane DOE K.C. 1’s and Plaintiff Jane DOE A.H. 2’s values

17 of trust and confidence in others and has caused Plaintiff Jane DOE K.C. 1 and Jane DOE A.H. 2

18 substantial emotional distress, anxiety, nervousness, anger and fear.

19 213. As a direct result of the molestation by Defendant DOE 1 and Defendant DOE 2,
20 Plaintiff Jane DOE K.C. 1 and Plaintiff Jane DOE A.H. 2 each have had issues with their personal

21 lives, such as issues with trust and control. These feelings have caused Plaintiff Jane DOE K.C. 1 and

22 Plaintiff Jane DOE A.H. 2 each substantial emotional distress, guilt, anxiety, nervousness and fear.

23 214. In subjecting Plaintiff Jane DOE K.C. 1 and Plaintiff Jane DOE A.H. 2 to the wrongful
24 treatment herein described, Defendant DOE 1 and Defendant DOE 2 acted willfully and maliciously

25 with the intent to harm Plaintiff Jane DOE K.C. 1 and Plaintiff Jane DOE A.H. 2, and in conscious

26 disregard of Plaintiff Jane DOE K.C. 1’s and Plaintiff Jane DOE A.H. 2’s rights, so as to constitute

27 malice and oppression under California Civil Code § 3294. Plaintiff Jane DOE K.C. 1 and Plaintiff

28 Jane DOE A.H. 2 each are therefore entitled to the recovery of punitive damages, in an amount to be

- 28 -
COMPLAINT
 1 determined by the court, against Defendant DOES 1 – 50, in a sum to be shown according to proof.

2 PRAYER FOR RELIEF

3 Wherefore, Plaintiffs Jane DOE K.C. 1 and Plaintiff Jane DOE A.H. 2 pray for Judgment
4
against Defendants as follows:
5
1. For past, present and future general damages in an amount to be determined at trial;
6
2. For past, present and future special damages, including but not limited to past,
7
present and future lost earnings, economic damages and others, in an amount to be
8

9 determined at trial;

10 3. Any appropriate statutory damages, including but not limited to attorneys’ fees;
11 4. For costs of suit;
12
5. For pre- and post- judgment interest as allowed by law;
13
6. For attorneys’ fees pursuant to the aforementioned statutes and otherwise allowable
14
by law:
15

16 a. California Code of Civil Procedure § 1021.5;

17 7. For exemplary and punitive damages in an amount to be determined at trial; and

18 8. For such other and further relief as the court may deem proper.
19

20
DATED: December 29, 2022 KBM LAW CORP.
21

22
_________________________________
23 KAREN BARTH MENZIES
24

25 ALAN LESCHT AND ASSOCIATES, P.C.

Ari Wilkenfeld
26 Laura Nagel
Caroline Whitlock
27
Attorneys for Plaintiffs Jane DOE K.C. 1 and
28 Jane DOE A.H. 2

- 29 -
COMPLAINT
 1 DEMAND FOR JURY TRIAL

2 A trial by jury is hereby demanded by Plaintiff.

3

4 DATED: ______________ KBM LAW CORP.

5

6 ____________________________
KAREN BARTH MENZIES
7

8 ALAN LESCHT AND ASSOCIATES, P.C.

Ari Wilkenfeld
9 Laura Nagel
10 Caroline Whitlock

11 Attorneys for Plaintiffs Jane DOE K.C. 1 and

Jane DOE A.H. 2
12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

- 30 -
COMPLAINT