1 00:00:00,080 --> 00:00:02,680 Speaker 1: What's up, everyone, and welcome to another episode of The 2 00:00:02,799 --> 00:00:06,000 Diddy Diaries. In this episode, we're picking up where we 3 00:00:06,080 --> 00:00:13,080 left off with Ashley Parum's amended complaint naming Ditty, drewski Odell, Beckham, Jaguar, 4 00:00:13,160 --> 00:00:17,760 Wright and others. Second cause of action Violations of Racketeer 5 00:00:17,760 --> 00:00:22,199 Influenced and Corrupt Organizations Act RICO Conspiracy US Code eighteen, 6 00:00:22,320 --> 00:00:28,199 nineteen sixty two d Plaintiffs against all defendants. Plaintiff incorporates 7 00:00:28,199 --> 00:00:31,359 by reference and realleges, each of the preceding paragraphs and 8 00:00:31,440 --> 00:00:34,799 all paragraphs below, as though fully set forth and brought 9 00:00:34,799 --> 00:00:38,000 in this cause of action. Each defendant agreed to commit 10 00:00:38,280 --> 00:00:43,200 the substantative racketeering offense through agreeing to participate in racketeering acts. 11 00:00:43,640 --> 00:00:47,399 Each enterprise member agreed to commit the substantative racketeering offense 12 00:00:47,679 --> 00:00:51,920 through agreeing to participate in racketeering acts. Each defendant knew 13 00:00:51,960 --> 00:00:54,880 the general status of the conspiracy was to enable the 14 00:00:54,960 --> 00:00:57,920 cover and cover up defend in Ditty's decades worth of 15 00:00:57,960 --> 00:01:02,320 sexual abuse. Each enterprise member knew the general status of 16 00:01:02,359 --> 00:01:06,079 the conspiracy was to enable and cover up the ditties 17 00:01:06,120 --> 00:01:09,719 decades worth of sexual abuses. Each defendant member knew the 18 00:01:09,719 --> 00:01:14,000 conspiracy extended beyond their individual role as set forth above. 19 00:01:14,040 --> 00:01:17,879 Each defendant agreed and conspired to violate US Code Section 20 00:01:18,200 --> 00:01:22,040 nineteen sixty two C, specifically in an effort to enable 21 00:01:22,359 --> 00:01:26,799 further protect aid, secrete, and cover up each of Defendant 22 00:01:26,799 --> 00:01:31,959 Ditty's sexual assaults, defending Ditty's pattern and practice of sexual assault, kidnapping, 23 00:01:31,959 --> 00:01:36,359 an abuse, and defending Ditty's sexual battery against plaintiffs, Defendants 24 00:01:36,359 --> 00:01:40,120 agreed to engage in each of the predicate offenses identified above. 25 00:01:40,879 --> 00:01:43,599 Defendants knew their predicate acts were a part of a 26 00:01:43,879 --> 00:01:47,040 pattern of racketeering activity and agreed to the commission of 27 00:01:47,079 --> 00:01:51,319 those acts to further the schemes described above, constituting a 28 00:01:51,359 --> 00:01:55,560 conspiracy to violate US Code eighteen, section nineteen sixty two C, 29 00:01:56,319 --> 00:01:59,799 in violation of US Code eighteen, Section nineteen sixty two D. 30 00:02:01,239 --> 00:02:05,760 Third Cause of Action Civil Code Section one seventy zero 31 00:02:05,799 --> 00:02:11,439 eight dot five Sexual Battery Plaintiffs against Defendant Ditty, Shane, Odell, Drewski, 32 00:02:11,439 --> 00:02:15,479 and Valdez. Plaintiff incorporates by reference and realleges, each of 33 00:02:15,520 --> 00:02:19,319 the preceding paragraphs and all paragraphs below, as though fully 34 00:02:19,319 --> 00:02:22,919 set forth and brought in this cause of action. Defendants 35 00:02:22,919 --> 00:02:26,080 committed acts with the intent to cause a harmful or 36 00:02:26,120 --> 00:02:30,439 offensive contact with an intimate part of plaintiff. The sexually 37 00:02:30,439 --> 00:02:34,639 offensive and unwonted contact with plaintiff directly resulted from defendants 38 00:02:34,639 --> 00:02:40,400 set acts. Defendant Ditty exploited his position of authority to intimidate, overwhelm, 39 00:02:40,599 --> 00:02:44,919 and subdue plaintiffs with the assistance of defendants Shane kk 40 00:02:45,400 --> 00:02:50,159 Odell Brandy, and Drewski. Objections to his conduct would have 41 00:02:50,159 --> 00:02:54,080 been met with retaliation. Defendant Ditty abused his position of 42 00:02:54,120 --> 00:02:56,560 power and authority over a plaintiff Parum, who was in 43 00:02:56,639 --> 00:02:59,680 no position to reject his sexual assault due to word 44 00:02:59,680 --> 00:03:03,280 being fit, physically outnumbered, unable to vacate the premises because 45 00:03:03,280 --> 00:03:06,439 she was drugged and having her clothes, purse, cell phone, 46 00:03:06,680 --> 00:03:10,759 and keys hidden from her. Defendant Didty abused his position 47 00:03:10,840 --> 00:03:13,719 of power and authority over plaintiff John Doe, who was 48 00:03:13,759 --> 00:03:16,520 in no position to reject his sexual assault due to 49 00:03:16,599 --> 00:03:20,199 him being physically outnumbered, unable to vacate the premises because 50 00:03:20,199 --> 00:03:22,680 he was drugged and kidnapped, and having his cell phone 51 00:03:22,680 --> 00:03:26,879 and keys hidden from him. Defendant Valdez abused his position 52 00:03:26,919 --> 00:03:29,520 of power and authority over plaintif Jane Doe, who was 53 00:03:29,560 --> 00:03:32,680 in no position to reject his sexual assault due to 54 00:03:32,719 --> 00:03:36,560 her being physically outnumbered, unable to vacate the premises because 55 00:03:36,599 --> 00:03:39,560 she was drugged and kidnapped and having her cell phone 56 00:03:39,560 --> 00:03:43,360 and keys hidden from her defendant Didty Shane Odell and 57 00:03:43,439 --> 00:03:47,479 Drewski's battery on plaintiff caused physical injury, severe mental and 58 00:03:47,560 --> 00:03:51,599 emotional distress, pain and suffering, mental anguish, and loss of 59 00:03:51,719 --> 00:03:56,080 enjoyment of life. Defendants on lawful actions were intentional, done 60 00:03:56,080 --> 00:03:59,479 with malice, and or showed a deliberate, wilful, wanton, and 61 00:03:59,599 --> 00:04:04,680 reckless indifference to Plaintiff's rights. Plaintiff claims compensentory and punitive 62 00:04:04,759 --> 00:04:08,360 damages herein. The amount of damages sought herein exceeds the 63 00:04:08,439 --> 00:04:12,800 jurisdictional limits of all other courts which would otherwise have jurisdiction. 64 00:04:13,199 --> 00:04:17,160 Fourth cause of action California Civil Code, Section three forty 65 00:04:17,279 --> 00:04:22,079 dot sixteen, Sexual Assault Plaintiff parum against defendants Ditty, Shane 66 00:04:22,160 --> 00:04:26,360 O'Dell and Drewski. Plaintiff incorporates by reference and realleges, each 67 00:04:26,399 --> 00:04:30,000 of the preceding paragraphs and all paragraphs below as though 68 00:04:30,040 --> 00:04:32,600 fully set forth and brought in this cause of action. 69 00:04:33,480 --> 00:04:36,600 Defendant touched an intimate part of plaintiff against her will 70 00:04:36,839 --> 00:04:40,839 for a sexual arousal, sexual gratification, or a sexual abuse. 71 00:04:42,680 --> 00:04:46,319 Defendants committed an act of sexual penetration against Plaintiff's will 72 00:04:46,480 --> 00:04:50,279 by means of force, drugging, violence, duress, menace, or fear 73 00:04:50,600 --> 00:04:55,000 of immediate and unlawful bodily injury to a plaintiff. Defendant's 74 00:04:55,040 --> 00:04:58,839 conduct places plaintiff in a reasonable apprehension of bodily harm. 75 00:04:59,399 --> 00:05:03,040 Defendants act actions caused plaintiff to fear retaliation in the future, 76 00:05:03,279 --> 00:05:07,519 and there was a reasonable possibility that defendants, specifically Defendant Ditty, 77 00:05:07,720 --> 00:05:12,040 could execute on a threat of retaliation. Defendants assault on 78 00:05:12,079 --> 00:05:16,519 plaintiff caused physical injury, severe mental and emotional distress, pain 79 00:05:16,600 --> 00:05:19,920 and suffering, mental anguish, and loss of enjoyment of life. 80 00:05:20,399 --> 00:05:23,920 Defendants on lawful actions were intentional, done with malice, and 81 00:05:24,000 --> 00:05:27,600 are with a deliberate, wilful, wanton, and reckless indifference to 82 00:05:27,600 --> 00:05:32,319 Plaintiff's rights. Defendant conspired to and did engage in a 83 00:05:32,399 --> 00:05:35,600 cover up or attempted cover up of previous instances of 84 00:05:35,720 --> 00:05:40,480 allegations of sexual assault by defendant Ditty. Newly enacted CCP 85 00:05:40,639 --> 00:05:44,959 three forty dot sixteen, effect of January first, twenty twenty three, 86 00:05:45,319 --> 00:05:48,800 is a governing California state statute extending the Statute of 87 00:05:48,800 --> 00:05:52,560 Limitations in granting revival of a plaintiff claim seeking to 88 00:05:52,560 --> 00:05:56,160 recover damages suffered as a result of a sexual assault 89 00:05:56,199 --> 00:05:59,759 that occurred on plaintiff. The amount of damages sought herein 90 00:06:00,079 --> 00:06:03,279 seedes the jurisdictional limits of all other courts which would 91 00:06:03,279 --> 00:06:08,319 otherwise have jurisdiction. Fifth cause of action California's Civil Code, 92 00:06:08,360 --> 00:06:12,560 Section fifty one dot nine Sexual Harassment Plaintiff parum against 93 00:06:12,560 --> 00:06:17,399 defendants Ditty, Shane Odell, and Drewski. Plaintiff incorporate by reference 94 00:06:17,399 --> 00:06:20,160 and re allege each of the preceding paragraphs and all 95 00:06:20,240 --> 00:06:23,560 paragraphs below as though fully set forth and brought in 96 00:06:23,639 --> 00:06:29,360 this cause of action. Defendants made sexual advances, solicitations, sexual requests, 97 00:06:29,399 --> 00:06:34,279 demands for sexual compliance by plaintiff, as well as engaged 98 00:06:34,279 --> 00:06:37,879 in other verbal, visual, or a physical conduct of sexual 99 00:06:38,000 --> 00:06:41,360 nature or of a hostile nature based on Plaintiff's gender, 100 00:06:41,839 --> 00:06:46,279 all of which were unwelcome and pervasive or severe. Defendants intentionally, 101 00:06:46,399 --> 00:06:50,240 recklessly and wantonly acts resulted in harmful and offensive contact 102 00:06:50,279 --> 00:06:54,759 with the intimate parts of Plaintiff's persons. Defendant Ditty specifically 103 00:06:54,839 --> 00:06:58,319 used his authority to coerce and to exploit Defendant Shane 104 00:06:58,600 --> 00:07:00,839 into a learning plaintiff to his home so that Defendant 105 00:07:00,839 --> 00:07:05,319 Ditty could physically, psychologically, and or emotionally through force, manipulation, 106 00:07:05,720 --> 00:07:11,759 emotional abuse, intimidation, and retaliation abuse Plaintiff. These acts were 107 00:07:11,759 --> 00:07:16,959 done for defending Ditty's sexual gratification. Plaintiffs suffered economic loss 108 00:07:17,560 --> 00:07:21,439 or disadvantage and or personal injury, including but not limited 109 00:07:21,480 --> 00:07:25,879 to emotional distress, as a result of defendant's conduct. As 110 00:07:25,879 --> 00:07:29,240 a result of defendants on lawful conduct, Plaintiff is entitled 111 00:07:29,240 --> 00:07:33,759 to actual damages and exemplary damages pursuant to California Code 112 00:07:33,800 --> 00:07:37,240 Section fifty two, Subdivision B, in an amount to be 113 00:07:37,240 --> 00:07:42,040 awarded at trial. Six. Cause of action Battery Plaintiff against 114 00:07:42,079 --> 00:07:45,680 all defendants. Plaintiffs incorporate by reference and re allege each 115 00:07:45,720 --> 00:07:49,319 of the preceding paragraphs and all paragraphs below, as though 116 00:07:49,319 --> 00:07:51,720 fully set forth and brought in this cause of action. 117 00:07:52,399 --> 00:07:56,199 Defendants intended to commit and committed acts of unwanted contact 118 00:07:56,199 --> 00:08:00,560 with plaintiffs. Defendant Ditty Shane O'Dell and Drewski committed unwanted 119 00:08:00,560 --> 00:08:04,120 contact with Plaintiff Parum in a harmful and offensive manner, 120 00:08:04,399 --> 00:08:08,439 including but not limited to, by inflicting sexual abuse against plaintiff, 121 00:08:09,439 --> 00:08:13,079 among other batteries. Defending KK and Brandy abuse Plaintiff Parum 122 00:08:13,120 --> 00:08:18,360 without her consent and without equality. Defendant Peltae, Gonzales, Valdez, 123 00:08:18,399 --> 00:08:22,759 Helena and Jaguarre committed unwanted contact with Plaintiff's Doe in 124 00:08:22,839 --> 00:08:26,199 a harmful and offensive manner, including but not limited to, 125 00:08:26,319 --> 00:08:31,600 by inflicting severe physical abuse against plaintiffs. Defendant Ditty committed 126 00:08:31,800 --> 00:08:35,080 unwanted contact with Plaintiff John Doe in a harmful and 127 00:08:35,159 --> 00:08:38,799 offensive manner, including but not limited to, by inflicting sexual 128 00:08:38,799 --> 00:08:43,399 abuse against plaintiff. Defendant Ditty exploited his position and status 129 00:08:43,440 --> 00:08:47,159 to intimidate, overwhelm, and subdued plaintiffs. Any objections to his 130 00:08:47,240 --> 00:08:50,639 conduct would be met with retaliation not only by plaintiffs, 131 00:08:50,720 --> 00:08:54,440 but by other defendants involved. Defendant Didty abused his position 132 00:08:54,480 --> 00:08:57,840 of power and influence over Plaintiff Parum and John Doe, 133 00:08:57,960 --> 00:08:59,919 who were in no position to reject his sexual if 134 00:09:01,200 --> 00:09:05,240 Defendants batteries on plaintiff cause physical injury, severe mental and 135 00:09:05,279 --> 00:09:09,279 emotional distress, pain and suffering, mental anguish, and loss of 136 00:09:09,360 --> 00:09:13,399 enjoyment of life. Defendants on lawful actions were intentional, done 137 00:09:13,440 --> 00:09:16,639 with malice, and or showed a deliberate, wilful, wanton, and 138 00:09:16,840 --> 00:09:22,240 reckless indifference to plaintiff's rights. Plaintiffs claim compensentory and punitive 139 00:09:22,320 --> 00:09:26,519 damages herein. The amount of damages sought herein exceeds the 140 00:09:26,600 --> 00:09:30,840 jurisdictional limits of all other courts which would otherwise have jurisdiction. 141 00:09:31,600 --> 00:09:36,879 Seventh cause of action Assault Plaintiffs against all defendants. Plaintiffs 142 00:09:36,879 --> 00:09:39,600 incorporate by reference and re allege each of the preceding 143 00:09:39,639 --> 00:09:43,080 paragraphs and all paragraphs below as though fully set. Fourth, 144 00:09:43,320 --> 00:09:48,240 and broaden this cause of action. Defendants intentionally attempted, threatened, 145 00:09:48,559 --> 00:09:52,320 and committed harmful and offensive contacts against plaintiffs, including but 146 00:09:52,399 --> 00:09:56,480 not limited to, inflicting sexual abuse and physical abuse against plaintiffs. 147 00:09:57,120 --> 00:10:01,559 Defendant's conduct placed plaintiffs, and reasonable apprehension of bodily harm. 148 00:10:02,000 --> 00:10:05,960 Defendant's assaults on plaintiffs cause physical injury, severe mental and 149 00:10:06,000 --> 00:10:09,799 emotional distress, pain and suffering, mental anguish, and loss of 150 00:10:09,879 --> 00:10:14,759 enjoyment of life. Defendants on lawful actions were intentional, done 151 00:10:14,799 --> 00:10:17,840 with malice and or show to deliberate, wilful, wanton, and 152 00:10:17,919 --> 00:10:22,799 reckless indifference to Plaintiffs' rights. Plaintiff claims compensentory and punitive 153 00:10:22,879 --> 00:10:26,879 damages here in. The amount of damages sought herein exceeds 154 00:10:26,879 --> 00:10:30,480 the jurisdictional limits of all other courts which would otherwise 155 00:10:30,679 --> 00:10:33,600 have jurisdiction. All right, we're going to wrap up right here, 156 00:10:33,720 --> 00:10:35,360 and in the next episode we're going to pick up 157 00:10:35,360 --> 00:10:37,759 with the eighth cause of action. If you'd like to 158 00:10:37,799 --> 00:10:40,000 contact me, you can do that at Bobby Kopucci at 159 00:10:40,000 --> 00:10:43,399 protonmeil dot com. That's bo b b Y c ap 160 00:10:43,759 --> 00:10:47,080 u Cci at ProtonMail dot com, or if you prefer, 161 00:10:47,120 --> 00:10:51,240 you can find me on x at Bobby Underscore cap 162 00:10:51,840 --> 00:10:54,919 use Cci. All of the links that we discussed can 163 00:10:54,960 --> 00:10:58,159 be found in the description box. What's up, everyone, and 164 00:10:58,240 --> 00:11:02,080 welcome to another episode of the Diaries. In this episode, 165 00:11:02,080 --> 00:11:05,559 we're again right back too that Ashley Parum amended complaint 166 00:11:06,000 --> 00:11:11,080 against Ditty, Drew, Ski, Odell, Beckham, Jaguar, Wright and others. 167 00:11:11,879 --> 00:11:16,720 Eighth cause of action Negligence Plaintiff Parum against defendant Shine 168 00:11:16,799 --> 00:11:20,320 Plaintiff incorporates by reference and realleges, each of the preceding 169 00:11:20,799 --> 00:11:24,039 and all paragraphs below is though fully set forth and 170 00:11:24,120 --> 00:11:27,720 brought in this cause of action. Defending Shane invited plaintiff 171 00:11:27,759 --> 00:11:31,080 to his home as a guest. Defending Shain owed plaintiff 172 00:11:31,080 --> 00:11:35,279 a right to expect protection from the other defendants, specifically 173 00:11:35,320 --> 00:11:38,919 defendant Ditty while a guest at his home. As a 174 00:11:38,960 --> 00:11:42,279 direct and proximate result of the foregoing negligence, Plaintiff was 175 00:11:42,320 --> 00:11:46,080 sexually harassed, assaulted, and abused by defendants Ditty Shane in 176 00:11:46,120 --> 00:11:50,480 those one and two, causing plaintiff bodily injuries, pain and suffering, 177 00:11:50,799 --> 00:11:54,799 mental anguish, and loss of capacity for the enjoyment of life. 178 00:11:54,879 --> 00:11:58,480 The losses are either permanent or continuing, and plaintiff will 179 00:11:58,519 --> 00:12:02,720 suffer losses in the future. Ninth cause of action negligent 180 00:12:02,759 --> 00:12:11,360 failure to warn plaintiff against defendant Shain, KK Pelatier, Gonzales, Valdez, Odell, Drewski, Jaguar, Helena, 181 00:12:11,759 --> 00:12:16,000 Brandy En Dooz. Plaintiff incorporates by reference and realleges, each 182 00:12:16,039 --> 00:12:18,960 of the preceding and all paragraphs below as though fully 183 00:12:18,960 --> 00:12:22,480 set forth and brought in a cause of action defendant's 184 00:12:22,519 --> 00:12:26,000 conduct created a risk of physical or emotional harm to plaintiffs. 185 00:12:26,559 --> 00:12:29,600 Defendants knew and had reason to know that Plaintiff Parum 186 00:12:29,799 --> 00:12:32,320 and John Doe were at risk of sexual assault and 187 00:12:32,399 --> 00:12:36,000 abuse by defendant Ditty. Despite the knowledge of the danger 188 00:12:36,320 --> 00:12:38,840 in the participation in the Ditty sexual abuse and cover 189 00:12:38,919 --> 00:12:42,159 up enterprise, defendants did not alert plaintiff to the risk 190 00:12:42,399 --> 00:12:46,679 of sexual assault, harassment, kidnapping, physical assault, rape, and or 191 00:12:46,759 --> 00:12:50,799 other attacks by defendant Ditty. In fact, defendants facilitated and 192 00:12:50,879 --> 00:12:55,679 assisted defendant Ditty in his illegal, devian activities and despicable behavior. 193 00:12:56,440 --> 00:13:01,120 Defendant Pelletier represented he was lawfully transporting plaintiff Dose for 194 00:13:01,159 --> 00:13:05,600 the purpose of outstanding warrants. Defendant Chains specifically represented to 195 00:13:05,679 --> 00:13:08,320 plaintiff that she would be safe while guest in his 196 00:13:08,399 --> 00:13:11,840 home and would be free of risk of attack. Defendants 197 00:13:11,840 --> 00:13:14,399 had reason to know that plaintiffs would be unaware of 198 00:13:14,440 --> 00:13:18,519 the risk of sexual assault, harassment, kidnapping, physical abuse, and 199 00:13:18,559 --> 00:13:22,519 cover up enterprise. A warning to plaintiffs by any defendant 200 00:13:22,519 --> 00:13:25,759 that they were at risk of sexual assault, harassment, kidnapping, 201 00:13:25,799 --> 00:13:29,320 physical assault, rape, and or other attacks by defendant Ditty 202 00:13:29,639 --> 00:13:32,519 or any other defendant would have reduced the risk of 203 00:13:32,559 --> 00:13:36,159 harm to plaintiffs. As a legal and direct result of 204 00:13:36,200 --> 00:13:41,440 the aforementioned conduct and omission of defendants, Plaintiffs were sexually assaulted, harassed, kidnapped, 205 00:13:41,440 --> 00:13:44,960 physically assaulted, raped, and or otherwise attacked and robbed of 206 00:13:45,000 --> 00:13:49,720 their dignity and personal safety. The depraved attacks on plaintiff 207 00:13:49,759 --> 00:13:53,960 caused plaintiff to suffer serious psychological and physical harm from 208 00:13:54,000 --> 00:13:57,279 which she may never fully recover. As a direct and 209 00:13:57,360 --> 00:14:01,080 legal result, a defendant's failure to warn, plaintiff suffered damages, 210 00:14:01,240 --> 00:14:05,159 both economic and general non economic damages. According to proof 211 00:14:05,919 --> 00:14:11,240 tenth cause of Action Negligent supervision and Retention Plaintiffs against 212 00:14:11,240 --> 00:14:15,320 Defendant Ditty, Plaintiff incorporates by reference and realleges, each of 213 00:14:15,320 --> 00:14:19,159 the preceding paragraphs and all paragraphs below, as though fully 214 00:14:19,159 --> 00:14:22,399 set forth and brought in this cause of action. At 215 00:14:22,399 --> 00:14:26,440 all times material defendants were employed by Defendant Ditty under 216 00:14:26,480 --> 00:14:30,799 the control and authority of Defendant Ditty. Defendants were unfit 217 00:14:31,039 --> 00:14:35,039 or incompetent and posed a particular risk of sexually harassing, assaulting, 218 00:14:35,320 --> 00:14:39,000 and or mentally abusing plaintiff. Defendant Ditty new or should 219 00:14:39,039 --> 00:14:42,559 have known, not only that defendants were unfit or incompetent 220 00:14:42,759 --> 00:14:46,440 and posed a particular risk of sexually harassing, assaulting, physically, 221 00:14:46,759 --> 00:14:50,480 and or mentally abusing plaintiffs, but also that this unfitness 222 00:14:50,679 --> 00:14:54,799 created a particular risk to plaintiffs. Defendants on fitness and 223 00:14:54,840 --> 00:14:59,279 particular risk to plaintiffs harmed plaintiffs. Defendant Ditty new or 224 00:14:59,320 --> 00:15:02,720 should have known that defendants Odell and Drewski had previously 225 00:15:02,759 --> 00:15:06,360 engaged and was continuing to engage an unlawful sexual conduct 226 00:15:06,519 --> 00:15:11,279 for his own personal sexual gratification. Defendant Ditty knew or 227 00:15:11,279 --> 00:15:14,159 should have known that it was foreseeable that defendants Odell 228 00:15:14,240 --> 00:15:17,639 and Drewski was engaging or would engage in illicit sexual 229 00:15:17,679 --> 00:15:21,320 activities with plaintiff under the cloak of the authority, confidence, 230 00:15:21,360 --> 00:15:25,080 and trust bestowed upon him through Defendant Ditty. At no 231 00:15:25,159 --> 00:15:28,200 time during the alleged period did Defendant Didty have in 232 00:15:28,240 --> 00:15:32,519 place a reasonable system or a procedure to investigate, supervise, 233 00:15:32,559 --> 00:15:37,240 and monitor defendants Odell Andrewski to prevent sexual and verbal 234 00:15:37,240 --> 00:15:41,039 abuse sexual assault, nor did he implement a system or 235 00:15:41,080 --> 00:15:44,720 a procedure to oversee a monitor conduct towards individuals that 236 00:15:44,759 --> 00:15:49,600 they encountered. Defendant Ditty conspired to and did breach his 237 00:15:49,759 --> 00:15:52,919 duties of care ode to plaintiff, including by turning a 238 00:15:52,960 --> 00:15:57,480 blind eye and encouraging known abuses by defendants Odell Andrewski 239 00:15:58,080 --> 00:16:01,200 and the known dangerous conditions of the Ditty sexual enterprise, 240 00:16:01,919 --> 00:16:05,320 and by continuing to expose individuals like Plaintiff Parum and 241 00:16:05,440 --> 00:16:09,080 John Doe to these dangers for decades. Even though defendant 242 00:16:09,080 --> 00:16:11,919 Ditty knew or should have known of the sexual illicit 243 00:16:11,960 --> 00:16:15,759 activities by himself and defendants Odell and Drewski, he failed 244 00:16:15,759 --> 00:16:20,000 to use reasonable care in supervising defendants Odell Andrewski and 245 00:16:20,080 --> 00:16:24,519 did nothing to reasonably investigate supervisor monitor defendants Odell and 246 00:16:24,600 --> 00:16:29,120 Drewski to ensure the safety of individuals they encountered. Defending 247 00:16:29,159 --> 00:16:32,639 Ditty's negligence in supervising and or attaining defendants Odel and 248 00:16:32,720 --> 00:16:36,559 Drewski was a substantial factor in causing harm to plaintiff. 249 00:16:37,480 --> 00:16:40,320 As a result of the above described conduct, Plaintiff has 250 00:16:40,360 --> 00:16:45,320 expended significant costs on therapy and suffered damages, including deprivation 251 00:16:45,399 --> 00:16:49,960 of income and benefits, loss of employment opportunities, severe physical 252 00:16:50,120 --> 00:16:54,759 and emotional distress, pain and suffering, mental anguish, humiliation, loss 253 00:16:54,759 --> 00:16:58,440 of enjoyment of life and damage to a reputation and career. 254 00:16:59,159 --> 00:17:03,159 Plaintiff's componenty I Punitive damages herein and the amount of 255 00:17:03,240 --> 00:17:06,519 damages sought herein exceeds the jurisdiction limits of all other 256 00:17:06,640 --> 00:17:11,279 courts which would otherwise have jurisdiction Eleven. Cause of action 257 00:17:11,640 --> 00:17:15,960 Intentional infliction of emotional distress. Plaintiff incorporates by reference and 258 00:17:16,000 --> 00:17:19,240 re alleges each of the preceding paragraphs and all paragraphs 259 00:17:19,240 --> 00:17:21,960 below as though fully set forth and brought in this 260 00:17:22,079 --> 00:17:25,960 cause of action. Defendants conspired to and did engage in 261 00:17:26,000 --> 00:17:29,839 conduct that was extreme and outrageous and intentionally caused severe 262 00:17:29,839 --> 00:17:34,960 emotional distress to plaintiffs. Defendant's conduct exceeded all possible bounds 263 00:17:34,960 --> 00:17:38,640 of decency. Defendants acted with the intent and knowledge that 264 00:17:38,680 --> 00:17:43,359 plaintiffs suffered emotional distress due to their inexcusable and outrageous conduct. 265 00:17:44,480 --> 00:17:48,480 Defendants conduct caused plaintiffs to suffer physical injury, severe mental 266 00:17:48,599 --> 00:17:52,319 and emotional distress, pain and suffering mental anguish, and loss 267 00:17:52,319 --> 00:17:56,119 of enjoyment of life. Defendants on lawful actions, were intentional, 268 00:17:56,279 --> 00:17:59,200 done with malice, and or showed a deliberate, willful, wanton 269 00:17:59,400 --> 00:18:03,880 and reckless indifference to Plaintiff's rights. Plaintiffs' claim competentory and 270 00:18:03,920 --> 00:18:08,359 punitive damages herein the amount of damages sought herein exceeds 271 00:18:08,400 --> 00:18:11,559 the jurisdictional limits of all other courts which would otherwise 272 00:18:11,599 --> 00:18:17,000 have jurisdiction. Twelfth cause of action negligent infliction of emotional distress. 273 00:18:17,640 --> 00:18:21,279 Plaintiff incorporates by reference and realleges, each of the preceding 274 00:18:21,359 --> 00:18:24,920 paragraphs and all paragraphs below, as though fully set forth 275 00:18:24,960 --> 00:18:28,440 and brought in this cause of action. Defendants were negligent 276 00:18:28,480 --> 00:18:31,440 by both conspiring to and each breaching the duty of 277 00:18:31,519 --> 00:18:34,079 care that they owed to plaintiffs to keep her safe, 278 00:18:34,319 --> 00:18:37,640 and by breaching their duty to properly supervise and control 279 00:18:37,680 --> 00:18:41,119 defendants within the ditty sexual abuse and cover up enterprise. 280 00:18:42,119 --> 00:18:45,960 Plaintiffs suffered physical injuries, severe mental and emotional distress, pain 281 00:18:46,079 --> 00:18:49,119 and suffering, mental anguish, and loss of enjoyment of life. 282 00:18:49,920 --> 00:18:53,480 Defendants negligence were a substantial factor in causing plaintiffs to 283 00:18:53,519 --> 00:18:58,039 suffer physical injuries, severe mental and emotional distress, pain and suffering, 284 00:18:58,119 --> 00:19:02,559 mental anguish, and the loss of enjoyment of life. Thirteenth 285 00:19:02,640 --> 00:19:07,200 cause of action on justin Richmond, plaintiff against defendant Shane KK, 286 00:19:07,359 --> 00:19:12,960 Pelotae Valdez, Brandy, Drewski, Helena, Odell, big homy c C. Jaguarre, 287 00:19:13,000 --> 00:19:17,119 and Doze. Plaintiffs incorporate by reference and re allege each 288 00:19:17,160 --> 00:19:20,799 of the preceding paragraphs and law paragraphs below as though 289 00:19:20,839 --> 00:19:23,359 fully set forth and brought in this cause of action. 290 00:19:24,119 --> 00:19:28,119 Defendan Shane receives significant revenue, specifically a new car, for 291 00:19:28,200 --> 00:19:31,880 his betrayal and his involvement in Plaintiff's assault, battery, rape, 292 00:19:32,000 --> 00:19:35,119 false imprisonment, and his role in the Ditty Sexual abuse 293 00:19:35,480 --> 00:19:41,640 and cover up enterprise. Defendants Pelote, Valdez, KK, Brandy, Helena, Jaguar, 294 00:19:41,720 --> 00:19:45,000 and Doze receive revenue in the form of cash payments 295 00:19:45,039 --> 00:19:49,440 for their involvement in plaintiff dose assault, battery, false imprisonment, 296 00:19:49,720 --> 00:19:52,000 and his role in the Ditty Sexual abuse and cover 297 00:19:52,119 --> 00:19:57,119 up enterprise. Other defendants named herein receive significant revenue for 298 00:19:57,160 --> 00:19:59,920 their involvement in Plaintiff's assault and their roles in the 299 00:20:00,000 --> 00:20:03,559 and the Ditty sexual abuse and cover up enterprise. Defendants 300 00:20:03,599 --> 00:20:06,720 appreciate and have knowledge of such benefits and retain them 301 00:20:06,720 --> 00:20:10,240 to this day under principles of equity and good conscience, 302 00:20:10,279 --> 00:20:13,720 Defendants should not be permitted to retain the profit they 303 00:20:13,759 --> 00:20:17,519 received and retained the plaintiff's expense while refusing to provide 304 00:20:17,559 --> 00:20:21,200 compensation for the injuries suffered by plaintiffs as a result 305 00:20:21,240 --> 00:20:24,799 of their own awful conduct, including their failure to guard against, 306 00:20:24,960 --> 00:20:28,599 educate as to, or otherwise failure to prevent such injuries 307 00:20:28,599 --> 00:20:33,200 inflicted on plaintiffs. Under principles of equity and good conscience, 308 00:20:33,240 --> 00:20:36,240 defendants should not be permitted to retain the profit they 309 00:20:36,279 --> 00:20:40,240 received and retained at plaintiff's expense while refusing to provide 310 00:20:40,279 --> 00:20:44,039 compensation for the injuries suffered by plaintiffs as a result 311 00:20:44,039 --> 00:20:46,799 of their own awful conduct as members of the Ditty 312 00:20:46,880 --> 00:20:51,400 sexual Abuse and cover up Enterprise. Plaintiffs seek restitution and 313 00:20:51,640 --> 00:20:55,279 or disgorgement of all money's defendants have unjustly received and 314 00:20:55,359 --> 00:20:58,039 retained as a result of their own awful conduct and 315 00:20:58,119 --> 00:21:01,680 participation in the Ditties, Sexual Abuse and cover up Enterprise. 316 00:21:01,720 --> 00:21:06,119 Alleged you're in fourteenth cause of action aiding and abetting 317 00:21:06,160 --> 00:21:10,079 plaintiff against all defendants. Plaintiffs incorporate by reference and re 318 00:21:10,160 --> 00:21:13,559 allege each of the preceding paragraphs and all paragraphs below 319 00:21:13,839 --> 00:21:16,279 as though fully set forth and brought in this cause 320 00:21:16,319 --> 00:21:20,119 of action. Defendants knew that an assault and battery sexual 321 00:21:20,160 --> 00:21:23,400 assault was being committed and was going to be committed 322 00:21:23,440 --> 00:21:27,039 against plaintiffs because of defendants involvement in the Ditty sexual 323 00:21:27,039 --> 00:21:31,640 abuse and cover up enterprise, Defendants provided drugs to be 324 00:21:31,720 --> 00:21:34,240 used to take advantage of plaintiffs without the knowledge or 325 00:21:34,319 --> 00:21:38,799 consent of plaintiffs. Defendants new plaintiffs have been and would 326 00:21:38,799 --> 00:21:41,880 be assaulted because of their involvement in the Ditty sexual 327 00:21:41,880 --> 00:21:45,759 abuse and cover up enterprise. Defendant's conduct was a substantial 328 00:21:45,799 --> 00:21:50,680 factor in causing harm to plaintiffs. Through aforementioned x, Defendants 329 00:21:50,680 --> 00:21:55,279 caused plaintiffs an imminent apprehension of harmful or offensive contact 330 00:21:55,400 --> 00:21:58,720 with an intimate part of Plaintiff's body and sexually offensive 331 00:21:58,720 --> 00:22:02,960 contact with plaintiff resulted. As a result of defendant's conduct, 332 00:22:03,000 --> 00:22:08,079 Plaintiff has suffered economic injury. Plaintiff's general, special, and consequential 333 00:22:08,160 --> 00:22:11,279 damages are in the amount to be proven at trial, 334 00:22:11,640 --> 00:22:14,319 but in no event is less than the minimum jurisdictional 335 00:22:14,359 --> 00:22:17,920 amount of this Court. As a result of defendants above 336 00:22:17,960 --> 00:22:21,359 describe conduct, plaintiffs have suffered and continues to suffer great 337 00:22:21,359 --> 00:22:24,359 emotional distress and was prevented and will continue to be 338 00:22:24,400 --> 00:22:28,599 prevented from performing daily activities and obtaining the full enjoyment 339 00:22:28,640 --> 00:22:32,319 of life. As described in this complaint, the defendant's conduct 340 00:22:32,359 --> 00:22:36,920 was done with oppression, fraud, and or malice, warranting significant damages, 341 00:22:37,160 --> 00:22:44,480 including punitive damages. Here plaintiffs were sexually assaulted by defendant Ditty, Shane, Odell, Drewski, 342 00:22:44,559 --> 00:22:49,839 Valdez Endo at defendant Chaine's residence. Plaintiff was legally on 343 00:22:49,880 --> 00:22:53,279 the premises as a guest and an invitee of defendant Shaine. 344 00:22:53,400 --> 00:22:57,319 Defended Shanine, through renting the premises, had dominion and control 345 00:22:57,640 --> 00:23:01,039 over the premises where a plaintiff was harmed. Defendant Didty 346 00:23:01,119 --> 00:23:05,720 had dominion and control over the actions of defending Shane, Odell, Drewski, 347 00:23:05,759 --> 00:23:08,160 and Dough and failed to step in and stop them 348 00:23:08,200 --> 00:23:11,559 from sexually assaulting plaintiff parum As owner of the property, 349 00:23:11,640 --> 00:23:14,240 Defending Shane had a duty to protect plaintiff from the 350 00:23:14,279 --> 00:23:17,720 harm she suffered at the hands of defendants Didty, Odell, Drewski, 351 00:23:18,079 --> 00:23:20,680 and Dough and breached his duty when he failed to 352 00:23:20,680 --> 00:23:24,519 stop them from sexually assaulting plaintiff. Parum. In furtherance of 353 00:23:24,559 --> 00:23:28,960 this breach, Defending Shane encouraged defendant Ditty, Odell, Drewski, and 354 00:23:29,160 --> 00:23:33,279 dough to continue their assault on plaintiff. Plaintiffs suffered immensely 355 00:23:33,359 --> 00:23:36,720 because of Defending Shane's intentional breach of his duty. Tour 356 00:23:37,359 --> 00:23:40,440 and Plaintiff Doughs were battered, sexually assaulted, and assaulted by 357 00:23:40,519 --> 00:23:46,000 defendants Didty, Pelletae, Gonzales, and Valdez at Defending Chaine's residence. 358 00:23:46,640 --> 00:23:49,440 Plaintiffs were legally on the premises as they were kidnapped 359 00:23:49,440 --> 00:23:53,279 and forcefully brought there. Defending Shane, through renting the premises, 360 00:23:53,400 --> 00:23:57,119 had dominion and control over the premises where plaintiffs were harmed. 361 00:23:57,480 --> 00:24:04,359 Defendant Didty had dominion and control over of defendant Shane, Odell, Drewski, Pelotier, Gonzales, 362 00:24:04,400 --> 00:24:07,000 and Valdez, and Doe failed to step in and stop 363 00:24:07,039 --> 00:24:10,559 them from assaulting and battering plaintiffs. As the owner of 364 00:24:10,599 --> 00:24:13,640 the property, Defending Shane had a duty to protect plaintiffs 365 00:24:13,680 --> 00:24:18,519 from the harm they suffered at the hands of defendant Ditty, Pelletier, Gonzales, 366 00:24:18,519 --> 00:24:21,519 and Valdez, and breach this duty when he failed to 367 00:24:21,519 --> 00:24:25,400 stop them from battering and assaulting plaintiff does. In furtherance 368 00:24:25,400 --> 00:24:28,960 of this breach, Defending Shine encouraged defendants to continue their 369 00:24:28,960 --> 00:24:33,079 assault on plaintiffs. Plaintiffs have suffered immensely because of Defending 370 00:24:33,119 --> 00:24:36,240 Shane's intentional breach of his duty to them. As a 371 00:24:36,279 --> 00:24:38,839 result of this breach of duty, plaintiffs have suffered and 372 00:24:38,880 --> 00:24:43,200 continue to suffer harm, including severe emotional distress, anxiety, and 373 00:24:43,319 --> 00:24:46,440 other consequential damages, for which they are entitled to an 374 00:24:46,440 --> 00:24:51,200 award of monetary damages and other relief. Defendant's conduct described 375 00:24:51,240 --> 00:24:55,279 above was wilful, wanton, and malicious At all relevant times. 376 00:24:55,559 --> 00:24:59,599 Defendants acted with conscious disregard for plaintiff's rights and feelings, 377 00:25:00,079 --> 00:25:02,880 acted with the knowledge of, or with reckless disregard for 378 00:25:02,960 --> 00:25:05,440 the fact that their conduct was certain to cause injury 379 00:25:05,519 --> 00:25:09,160 to plaintiffs and intended to cause fear, physical injury, and 380 00:25:09,319 --> 00:25:12,559 or pain and suffering to plaintiffs. By virtue of the foregoing, 381 00:25:12,599 --> 00:25:17,279 plaintiffs are entitled to recover punitive damages. All right, We're 382 00:25:17,279 --> 00:25:19,000 going to wrap up right here, and in the next 383 00:25:19,039 --> 00:25:21,559 episode we're gonna pick up with the fifteenth cause of action. 384 00:25:22,359 --> 00:25:24,039 If you'd like to contact me, you can do that 385 00:25:24,079 --> 00:25:27,640 at Bobby Kopuchi at ProtonMail dot com. That's bo b 386 00:25:27,759 --> 00:25:31,640 b Y c ap u Cci at protonmeil dot com, 387 00:25:32,000 --> 00:25:33,839 or if you prefer, you can find me on x 388 00:25:34,119 --> 00:25:39,000 at bo b b y underscore cap use Cci. All 389 00:25:39,039 --> 00:25:41,319 of the links that we discussed can be found in 390 00:25:41,359 --> 00:25:42,319 the description box.