DISTRICT COURT
CLARK COUNTY NEVADA
CASE NO: A-25-921868-C
Department 11
{K}
Plaintiff
v.
{D}
Defendant
COMPLAINT FOR DAMAGES
DEMAND FOR JURY TRIAL
Plaintiff Kat appearing in proper person, alleges as follows against
Defendant {D}
I. JURISDICTION AND VENUE
1. This Court has jurisdiction pursuant to the Constitution and laws of the State of
Nevada.
2. Venue is proper in Clark County because the events giving rise to this action
occurred in Las Vegas, Nevada. Defendant currently resides in Vermont but
committed tortious acts in Nevada, giving rise to long-arm jurisdiction under NRS
14.065.
II. PARTIES
3. Plaintiff Kat is an individual and resident of Clark County, Nevada.
4. Defendant {D} is an individual and former Nevada public official
who engaged in a personal relationship with Plaintiff and is responsible for the
conduct described herein.
III. FACTUAL ALLEGATIONS
5. On or about February 2, 2025, Plaintiff arranged what she believed would be a
consensual and respectful sexual encounter with Defendant at a hotel in Las
Vegas, Nevada. Plaintiff also invited a third party, a third party under Defendant’s
direction, and initially agreed to a video recording of the encounter, believing that
all parties would respect her boundaries and safety.
6. Upon arrival, Defendant consumed alcohol and cocaine, becoming increasingly
aggressive and dismissive of Plaintiff’s emotional cues and prior trauma
disclosures. He began exhibiting controlling, dehumanizing behavior that deviated
significantly from what Plaintiff had anticipated or agreed to.
7. Defendant intentionally restrained Plaintiff’s movement by using his body and
his surgically fused right wrist to hold her in place. Unlike a normal wrist joint,
which allows for ulnar and radial deviation (side-to-side movement), flexion, and
extension, Defendant's wrist lacked this normal mobility due to fusion. This
rigidity created a lever-like effect, making it more difficult for Plaintiff to wriggle
free or dislodge his grip. The abnormal anatomical stiffness added mechanical
strength to his hold, turning what would otherwise be a restrainable position into
an inescapable one, especially given Plaintiff’s state of distress and physical
vulnerability. Plaintiff attempted to roll away to escape the painful penetration,
but the rigidity of Defendant’s wrist prevented her from doing so.
8. Plaintiff physically attempted to move away and verbalized distress multiple
times. The recording, which had been initiated with Plaintiff’s consent, captured
her visible and audible agony. Defendant took no steps to stop the recording or to
protect Plaintiff’s welfare once she revoked consent. His failure to respond to her
distress constituted a gross abuse of power and disregard for her autonomy.
9. At some point during the encounter, a third party under Defendant’s direction
engaged in sexual activity with Plaintiff. Although Plaintiff had initially invited
the third party and consented to his presence, she had withdrawn all consent once the pain began. The third party’s participation occurred after this revocation and, upon information and belief, was done at Defendant’s direction and orchestration.
Defendant maintained control over the setting, and his orchestration of events
contributed directly to the continued violation of Plaintiff’s boundaries.
10. Throughout their relationship, Defendant raped Plaintiff repeatedly, using
emotional abuse, physical force, and manipulation to override her boundaries and
consent. He routinely engaged in emotionally abusive and threatening behavior.
He frequently threatened Plaintiff with physical violence and would make threats
of murder-suicide, particularly while under the influence of alcohol or drugs.
These threats were not isolated incidents but part of a sustained pattern of
intimidation and psychological control. Plaintiff lived in a state of constant fear,
unsure of when Defendant might act on his violent impulses. This environment of
coercion and volatility eroded Plaintiff’s sense of safety, autonomy, and ability to
assert boundaries, contributing substantially to the trauma she endured.
11. As a direct result of Defendant’s conduct, Plaintiff suffered severe
psychological trauma, including dissociation, flashbacks, panic attacks, and a
suicide attempt. She required intensive trauma therapy and was unable to work for
five months, incurring significant financial and emotional damages.
12. Prior to the incident, Plaintiff had engaged in consensual sexual activity with a
third party under Defendant’s direction. However, during the events captured in
the 40-minute video, Plaintiff began experiencing intense pain caused by vaginal
trauma inflicted earlier in the encounter by Defendant, including abrasions likely
caused by his fingernails.
13. As the pain increased, Plaintiff clearly asked for the sexual contact to stop.
Her requests were ignored by both Defendant and the third party, who continued the encounter without pause. At one point, the third party looked to Defendant and asked, “Are you sure she likes this?” In response, Defendant, without
consulting or checking on Plaintiff, inserted his fingers into her mouth and said,
“She loves it.”
14. Plaintiff was in visible and audible distress. She was no longer capable of
giving meaningful consent, and her objections were mocked and overridden. The
exchange between the third party and Defendant demonstrates a coordinated
disregard for Plaintiff’s autonomy and well-being, turning the encounter into a
prolonged and orchestrated, and controlled violation.
15. In addition to verbal protests, Plaintiff made a clear “time out” hand gesture
— a universally understood signal indicating the desire to pause or stop — during
the assault. This was a non-verbal yet unmistakable revocation of consent. Neither
Defendant nor the third party acknowledged or responded to the gesture. Their
failure to honor both verbal and non-verbal pleas for the contact to stop highlights
the deliberate nature of their actions and their disregard for Plaintiff’s autonomy
and suffering.
16. The incident was captured on a series of four videos. Three were recorded by
a third party, explicitly depicting the Defendant digitally penetrating the Plantiff
despite her pleas. The fourth video was recorded on the Plantiff’s mobile device
depicting both the Defendant and a third party engaged in sexual acts as the
Plantiff withdraws consent verbally as well as with hand gestures.
17. The Nevada State Police generated a report (Exhibit A) after receiving video
evidence related to the events of February 2, 2024. An arrest warrant was issued
by law enforcement following their review of the submitted video evidence and
associated materials. A true and correct copy of that warrant is attached hereto as
(Exhibit B). To Plaintiff’s knowledge, this warrant has not been executed. Its
issuance demonstrates a finding of probable cause by law enforcement regarding
the conduct at issue in this complaint. While that report references three video
recordings (Exhibits C, D, and E), a fourth video (Exhibit F) was later submitted
and confirmed as received, though not referenced in the report. All four videos are
preserved by the Plaintiff and are available upon court order or during discovery
I. Sexual Assault / Battery
18. Under Nevada law, sexual assault occurs when a person subjects another to
sexual penetration against the will of the victim, even if initial consent was given
and later withdrawn. (Nev. Rev. Stat. § 200.366(1)). Plaintiff initially consented to
sexual contact but explicitly and repeatedly revoked that consent once the act
became painful and overwhelming. She cried, screamed “No” and “Please stop,”
and attempted to physically disengage.
19. Despite Plaintiff’s clear withdrawal of consent, Defendant forcibly penetrated
her with his hand, restrained her with his body and fused wrist, and continued the
contact over her explicit objections. This conduct meets the legal definition of
sexual assault, as Defendant intentionally violated Plaintiff’s bodily autonomy
after consent had been revoked.
20. Moreover, the use of physical force to continue non-consensual contact
constitutes civil battery under Nevada common law, which defines battery as 'any
willful and unlawful use of force or violence upon the person of another.' (Nev.
Rev. Stat. § 200.481; State v. Luster, 111 Nev. 973 (1995)).
21. Plaintiff sustained significant physical trauma as a result of the assault,
including severe vaginal pain and swelling, as well as a disruption to her
reproductive health. Following the incident, Plaintiff experienced menstruation
twice a month for two consecutive months. These symptoms were consistent with
trauma-induced physiological dysregulation.
22. These physical injuries were directly caused by the forceful, non-consensual
penetration inflicted by Defendant. Plaintiff also suffered profound psychological
harm, including PTSD, panic attacks, dissociation, and suicidal ideation — all of
which required intensive therapeutic intervention.
23. The presence and involvement of a third party, a third party under Defendant’s
direction, occurred after Plaintiff had revoked consent. Upon information and
belief, the third party acted at Defendant’s direction. The third party’s actions
furthered the assault and aggravated the trauma. Defendant is liable for this
orchestrated and controlled assault as a principal actor and instigator under
conspiracy and joint liability doctrines (Dow Chem. Co. v. Mahlum, 114 Nev.
1468 (1998)).
24. Defendant’s conduct was egregious, violent, and executed with conscious
disregard for Plaintiff’s safety, bodily integrity, and autonomy. Plaintiff is entitled
to compensatory and punitive damages.
II. Intentional Infliction of Emotional Distress (IIED)
25. Under Nevada law, intentional infliction of emotional distress occurs when a
defendant engages in extreme and outrageous conduct that is intended to, or
recklessly causes, severe emotional distress to another. (Yeh v. Fujii, 143 Nev. 265
(2017); Nelson v. City of Las Vegas, 99 Nev. 548 (1983)).
26. Defendant’s actions — including forcibly penetrating Plaintiff after she
withdrew consent, ignoring her screams, physical resistance, and visible pain —
were not only intentional but also designed to dominate and humiliate. He
continued the assault while Plaintiff cried and screamed in distress, using his
physical advantage and her emotional vulnerability to exert control.
27. Defendant further aggravated Plaintiff’s suffering by directing or directing a
third party to continue in the sexual activity after Plaintiff had already revoked
consent. Plaintiff had invited the third party under a different understanding, and
his participation under Defendant’s direction constituted a betrayal of trust and
deepened the trauma.
28. The entire encounter, including the initial trust, the pain, the ignored pleas,
and the violation of Plaintiff’s autonomy, resulted in profound psychological
distress. Plaintiff suffered panic attacks, flashbacks, suicidal ideation, and a full
emotional collapse that necessitated long-term trauma therapy and caused her to
miss five months of work.
29. Defendant’s conduct was so extreme and outrageous that no reasonable person
in a civilized society would tolerate it. He is therefore liable for all emotional
damages sustained by Plaintiff under Nevada tort law.
III. Negligent Infliction of Emotional Distress (NIED)
30. Under Nevada law, a plaintiff may recover for negligent infliction of
emotional distress when the defendant's conduct negligently causes serious
emotional distress accompanied by physical symptoms. (Shoen v. Amerco, Inc.,
111 Nev. 735 (1995); State v. Eaton, 101 Nev. 705 (1985)).
31. Even assuming Defendant did not specifically intend to cause harm, his
conduct showed a reckless disregard for Plaintiff’s physical safety and emotional
well-being. He continued penetrating Plaintiff after she had clearly and repeatedly
withdrawn consent, despite her cries, pleas, and efforts to resist.
32. As a direct result of Defendant’s actions, Plaintiff experienced severe
emotional and physical responses, including uncontrollable crying, vomiting,
insomnia, dissociation, and a disrupted menstrual cycle marked by twice-monthly
bleeding for two months. She later attempted suicide and required long-term
trauma therapy.
33. Defendant owed Plaintiff a duty of reasonable care once he engaged in sexual
activity, particularly given the emotional vulnerability and power imbalance in
their relationship. His failure to exercise even basic consideration for her safety
and well-being resulted in lasting psychiatric injury for which he is liable.
IV . False Imprisonment
34. False imprisonment under Nevada law occurs when one person intentionally
confines another without lawful privilege and against the other’s consent. It does
not require physical barriers — the restriction of movement through force, threat,
or intimidation is sufficient. (Marschall v. City of Carson, 86 Nev. 107 (1970)).
35. During the assault, Plaintiff made repeated verbal and physical attempts to
disengage. She screamed, cried, said “No” and “Please stop,” and attempted to
move her body away.
36. Defendant intentionally restrained Plaintiff’s movement by using his body and
his fused wrist to hold her in place. Plaintiff attempted to roll away to escape the
painful penetration, but the abnormal rigidity of Defendant’s wrist — which
lacked normal ulnar or radial deviation — prevented the release of his grip.
37. Plaintiff reasonably believed she was not free to leave or protect herself. The
combination of Defendant’s physical control, her state of distress, and the
presence of a third party made it psychologically impossible to resist further.
Plaintiff felt powerless and trapped, resulting in panic, confusion, and
psychological trauma.
38. Defendant’s actions constitute intentional and unlawful restraint of Plaintiff’s
freedom of movement, satisfying the legal elements of false imprisonment.
Plaintiff is entitled to damages for this confinement and its emotional and
psychological impact.
V . PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests judgment against Defendant as
follows:
A. General and special damages in an amount to be determined at trial;
B. Punitive damages for willful and malicious conduct;
C. Declaratory Relief
That the Court enter a declaratory judgment stating that Defendant’s conduct, as
alleged herein, constituted that under Nevada law, including NRS 200.366, sexual
penetration without consent constitutes sexual assault regardless of whether the
parties were in a prior or ongoing intimate relationship, and that Plaintiff’s
withdrawal of consent rendered the Defendant’s continued actions unlawful.
D. Injunctive Relief
That the Court order Defendant to undergo a comprehensive psychological and
behavioral assessment by a licensed mental health professional approved by the
Court, and based on the findings, mandate participation in clinically appropriate
treatment programs, including individual psychotherapy, substance abuse
counseling, and anger management. Plaintiff further requests that these treatments
may occur in Defendant’s home state of Vermont, provided they meet Nevada
standards, and that Defendant provide periodic certified reports of compliance.
F. Costs of suit;
G. Such other and further relief as the Court deems just and proper.
EXHIBITS
Exhibit A – Nevada State Police Report, Case No. 24I000512
A true and correct copy of the report generated by the Nevada State Police concerning the
events of February 2, 2024. This report was created following receipt of video evidence
and materials provided by third parties. The report references three of four submitted
videos.
Exhibit B – Arrest Warrant (Not Executed) A true and correct copy of the arrest warrant
issued in connection with the assault of the Plaintiff. This warrant was generated by law
enforcement but, to Plaintiff’s knowledge, was not executed. It is included here as
evidence of the seriousness of the underlying allegations and the probable cause
determination by law enforcement.
Exhibit C – Video 1 (Referenced, Not Attached)
Video footage documenting the beginning of the assault. This video was submitted to the
Nevada State Police and is referenced in Exhibit A.
Exhibit D – Video 2 (Referenced, Not Attached)
A continuation of the assault, showing further non-consensual conduct. This video is
preserved and referenced in Exhibit A.
Exhibit E – Video 3 (Referenced, Not Attached)
A third segment showing escalating violence and the Plaintiff’s visible distress. This
video is referenced in Exhibit A.
Exhibit F – Video 4 (Submitted but Not Referenced in Report, Not Attached)
The final video, which was later located and submitted to the Nevada State Police.
Although acknowledged as received, it is not referenced in Exhibit A. This video remains
preserved in its original form
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