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Doe V Sharp Complaint

Plaintiff Jane Doe has filed a lawsuit against Defendant Shannon Sharpe, alleging that he manipulated, controlled, and ultimately raped her after a two-year relationship marked by intimidation and violence. The complaint details Sharpe's history of abusive behavior, including non-consensual recording of their sexual encounters and threats of violence. Doe seeks over $50 million in compensatory and punitive damages for the harm she suffered due to Sharpe's actions.

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keiji.hiramoto
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0% found this document useful (0 votes)
131 views14 pages

Doe V Sharp Complaint

Plaintiff Jane Doe has filed a lawsuit against Defendant Shannon Sharpe, alleging that he manipulated, controlled, and ultimately raped her after a two-year relationship marked by intimidation and violence. The complaint details Sharpe's history of abusive behavior, including non-consensual recording of their sexual encounters and threats of violence. Doe seeks over $50 million in compensatory and punitive damages for the harm she suffered due to Sharpe's actions.

Uploaded by

keiji.hiramoto
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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Electronically Filed

4/20/2025 10:25 PM
Steven D.Grierson
CLERK OF THE COURT
1 COMP
MICAH D. NASH
2 Nevada Bar No. 16596
[email protected]
3 DELAHUNTY & EDELMAN LLP
4 Embarcadero Center, Suite 1400
4 San Francisco, CA 94111 CASE NO:A-25-917246-C
Tel: (415) 891-6210 Department 11
5 Fax: (415) 891-6256
6 Anthony G. Buzbee (pro hac vice forthcoming)
[email protected]
7 Thomas Colby Holler (pro hac vice forthcoming)
[email protected]
8 THE BUZBEE LAW FIRM
J.P. Morgan Chase Tower
9 600 Travis, Suite 7500
Houston, Texas 77002
10 Telephone: (713) 223-5393
Facsimile: (713) 223-5909
11 Website: www.txattorneys.com

12 Attorneys for Plaintiff Jane Doe


13 IN THE EIGHTH JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA
14 IN AND FOR THE COUNTY OF CLARK
15
16
JANE DOE, an individual, Case No.
17
Plaintiff, Dept. No.
18 v.

19 SHANNON SHARPE, an individual,


ORIGINAL COMPLAINT AND JURY
20 Defendant. DEMAND

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28

DELAHUNTY & EDELMAN LLP


CALIFORNIA
COMPLAINT

Case Number:A-25-917246-C
1 Plaintiff Jane Doe complains of Defendant Shannon Sharpe, and for cause of action,
2 would respectfully show this Honorable Court the following:
3 I. INTRODUCTION
4 A woman can say “yes” to consensual sexual relations with a man ninety-nine times, but
5 when she says “no” even once, that “no” means no. Defendant Shannon Sharpe, a man who is
6 accustomed to getting what he wants, completely fails to understand this basic concept. After
7 many months of manipulating and controlling Plaintiff—a woman more than thirty years
8 younger than he—and repeatedly threatening to brutally choke and violently slap her, Sharpe
9 refused to accept the answer no and raped Plaintiff, despite her sobbing and repeated screams of
10 “no.”
11 Defendant Shannon Sharpe is a fifty-six-year-old former NFL superstar. He claims to be

12 one of the most successful sports media personalities in the country. Plaintiff is a young woman
13 in her early twenties. In 2023, Plaintiff was working out at a gym in Los Angeles, California,
14 when Sharpe approached her for the first time. Previously, Doe had noticed Sharpe watching her
15 during her workouts. At this time, Doe was just nineteen-years-old. At the time she did not know
16 who he was, only that he was another older man oggling her at the gym. Doe could tell Sharpe
17 was much older than her; she found him physically intimidating. Eventually, he introduced

18 himself. At his determined insistence, she gave him her number.


19 Over the next couple of weeks, Sharpe incessantly pursued Plaintiff. He constantly
20 approached her at the gym and attempted to contact her frequently with phone calls and text
21 messages asking to meet up, unwilling to take no for an answer. Eventually, Plaintiff gave in and
22 agreed to meet with Sharpe outside of the gym. However, before doing so, Sharpe demanded
23 that Doe sign a nondisclosure agreement, or NDA—something Plaintiff found a bit concerning.
24 She wondered why Sharpe was so insistent on her signing an NDA. She refused. Despite his
25 repeated efforts to get her to sign, she refused time and again. Eventually, he dropped the issue
26 and invited her to his house.
27 What followed was the beginning of a rocky consensual relationship that lasted nearly
28 two years. The relationship was very unequal—Sharpe is more than thirty years older, is
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1 considerably wealthier, is physically much larger, and exponentially stronger. Sharpe is famous
2 and has power.
3 Plaintiff and Sharpe saw each other on his terms, and on his schedule, as often as four
4 times a week. Over time, Plaintiff began to see Sharpe’s true nature. She found him to be
5 dishonest about his whereabouts. He would lie about seeing other women, while insisting to her
6 that she and he were exclusive. He often manipulated her, at times being sweet and loving to get
7 what he wanted, and at others times being angry and aggressive to achieve his goals. She
8 discovered over time that Sharpe was extremely emotional and possessed an uncontrollable
9 temper. He displayed the characteristics of a true narcissist. He wielded his power, his influence,
10 and his celebrity to control Plaintiff and get exactly what he wanted, whenever he wanted it, all
11 the while jealously guarding what he considered his for himself.

12 By October 2024 Sharpe’s behavior had grown progressively worse, beyond anything
13 Plaintiff had experienced with him before. At this point, he was insistent upon recording their
14 sexual activities, sometimes without her knowledge. Sharpe was also sharing the videos with
15 others, without her permission or knowledge. Sharpe would repeatedly tell Doe that he wanted
16 to do to her things that would “make no other man want her.” By this point, Sharpe was no longer
17 able to credibly maintain that the relationship was exclusive. (He had at this point “accidentally,”

18 or purposely to advance his career, went live on Instagram while having sex with another
19 woman.) Sharpe flew into fits of anger when Plaintiff noted his infidelity to their relationship,
20 or called him out about his extraneous activities. What had once been manipulation, control, and
21 intimidation now became something far more dangerous and sinister. Sharpe even figured out
22 how to get into Doe’s apartment complex without her permission. Sharpe made it clear that what
23 Doe wanted was of no moment, that Sharpe would get what he wanted, when he wanted it. In
24 October 2024, Shannon Sharpe violently sexually assaulted and anally raped Plaintiff two
25 different times in Las Vegas, Nevada, blatantly ignoring her requests for him to stop. He did it
26 again in January.
27
28
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COMPLAINT
1 Plaintiff left Nevada to temporarily escape Defendant Shannon Sharpe. She now seeks
2 justice through this action and other means. Plaintiff seeks compensatory and punitive damages
3 in this matter in excess of $50 million.
4 II. PARTIES
5 Plaintiff Jane Doe is an individual residing in Clark County, Nevada.
6 Defendant Shannon Sharpe is an individual residing in Clark County, Nevada. He may
7 be served at his residence at 2760 Tioga Pines Circle, Las Vegas, Nevada 89117 or wherever he
8 may be found.
9 III. JURISDICTION AND VENUE
10 Both Defendant and the Plaintiff reside here. The relief requested is within the minimum
11 jurisdictional limits of this Court. Pursuant to Nevada law, venue is proper in Clark County,

12 Nevada. This is the county where Defendant resides, and the acts, events, transactions, and
13 omissions that form the basis of this lawsuit occurred, in whole or in part, in Clark County,
14 Nevada.
15 IV. FACTUAL ALLEGATIONS RELATED TO ALL CLAIMS
16 A. Defendant Shannon Sharpe
17 Defendant Shannon Sharpe is a former NFL superstar and a well-known sports media

18 personality. After a fourteen-season career in the NFL, he is considered by some to be one of the
19 greatest tight ends of all time. He is a three-time Super Bowl champion and was recently inducted
20 into the NFL Hall of Fame.
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1
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11

12
13 Upon retirement, Sharpe transitioned into sports broadcasting, quickly achieving success
14 in the industry. Sharpe spent several years at CBS Sports before moving to Fox, where over a
15 decade he built a reputation for his strong opinions and hot takes. In 2023, Sharpe joined ESPN,
16 where he remains employed today. In addition to working at ESPN’s First Take, Sharpe hosts
17 his own widely followed podcast, interviewing high-profile athletes, entertainers, and public
18 figures. Sharpe claims he made as much as $6 million dollars from one episode of his podcast,
19 and is alleged to be signing a multi-million-dollar deal with The Volume media group.
20 Sharpe’s legacy extends beyond the field and media, and in one glaring area, it is not
21 good. Sharpe has a documented history of abusing and mistreating women. As an example, he
22 is currently a defendant in a lawsuit before the Supreme Court of New York,1 facing claims from
23 a woman of intentional infliction of emotional distress, among other allegations. Many of the
24 factual allegations in the New York case are eerily similar to his actions toward Plaintiff here.
25 According to the New York lawsuit, Sharpe forcefully subdued the plaintiff in that case,
26 forcing her to her knees and subjecting her to non-consensual oral sex, despite her repeated
27
1
28 Michele Evans v. Shannon Sharpe, No. 2023-100087 (Supreme Court of the State of New York, County of New
York, filed January, 27, 2023.)
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1 protests. When she resisted, he persisted. He would not take no for an answer. According to the
2 New York lawsuit, the plaintiff therein feared for her safety, just as Plaintiff fears for her safety
3 now. The New York lawsuit further alleges that Sharpe escalated to non-consensual vaginal
4 penetration, all while telling her that he would “make it so no other man would want [her].”
5 These words were apparently not a one-time thing. Plaintiff herein, too, has heard Sharpe say
6 those exact words to her.
7 In September 2024, Sharpe livestreamed himself “on accident” having sex with a woman.
8 Upon information and belief, he did so on purpose to seek media exposure and to attract social
9 media “views” and attention. To livestream himself, he would have had to deliberately “swipe
10 right” on Instagram to activate the live feed. Sharpe claims it was accidental, however discreetly
11 recording sex—without his partner’s knowledge—is something he is known to do; he did so with

12 the Plaintiff herein.


13 Plaintiff discovered that Sharpe had been secretly recording their sexual encounters
14 without her consent. When she confronted him, he summarily dismissed her concerns, claiming
15 the videos were for his own personal use. That, too, was a lie. Upon information and belief,
16 Sharpe on multiple occasions shared the recordings with his friends and associates. At one point,
17 he even forced Plaintiff to have sex with him while FaceTiming one of his childhood friends

18 named “Bucket”. Whenever Plaintiff would get up the courage to object to Sharpe’s outrageous
19 conduct—which was not often—he would aggressively and angrily “put her back in her place.”
20 Shannon Sharpe isn’t just a sports icon—he’s something far worse. He is a flawed,
21 narcissistic individual who has spent years using his fame, power, and influence to manipulate,
22 control, subjugate and violate women. With this suit, Plaintiff intends to put an end to this
23 egregious conduct.
24 B. January 2023: The Beginning of a Consensual—But Deeply Manipulative—
25 Relationship.
26 Sharpe first met Plaintiff at a Los Angeles gym in early 2023. Sharpe would deliberately
27 watch Doe in such a way to make sure she knew he was watching her.
28
5
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1 One day, as Plaintiff finished a set and turned around, she found Sharpe standing inches
2 behind her. Sharpe told her he had noticed her at the gym and wondered why she had not
3 introduced herself. This was the first time they spoke. Plaintiff at the time who had just turned
4 twenty years-old, was caught off guard, and was face to face with a fifty-four-year-old man she
5 had never met. Plaintiff did not know at the time who Shannon Sharpe was. She did not know
6 what to say nor how to feel about his advances.
7 During their first conversation, Sharpe proposed a challenge: a competition to see who
8 could “lean out” faster. The prize? If Plaintiff won, he would “buy her fake tits.” Plaintiff was
9 stunned. The implication that she needed or wanted such a thing was wildly inappropriate.
10 Hearing it from a stranger more than thirty years her senior made it even more disturbing.
11 Throughout their subsequent encounters at the gym, Sharpe made sure Plaintiff

12 understood who he was; a celebrity and TV personality.


13 Over the following weeks, Sharpe made himself unavoidable. He was at the gym when
14 she was. He constantly called and texted demanding she come to his Beverly Glen mansion.
15 Plaintiff repeatedly declined and made-up excuses to make her seem too busy to see him. But he
16 would not stop—Sharpe would not be deterred.
17 Eventually, Plaintiff gave in. But before she could meet him outside of the gym, Sharpe

18 made another demand—she had to sign a non-disclosure agreement, an “NDA.” He refused to


19 explain why and would not let her see a copy of the proposed agreement. He simply insisted she
20 sign one. Plaintiff refused. After multiple attempts, when he realized she would not cooperate,
21 he finally dropped the issue.
22 C. Revealed From the Start: The Violent, Aggressive, And Controlling Nature
23 of Shannon Sharpe.
24 The first night Plaintiff went to Sharpe’s house, the experience was unlike anything she
25 has dealt with before—disturbing, unsettling, and given his subsequent conduct, very
26 illuminating.
27 When Plaintiff arrived at his house, Sharpe opened the door to his Beverly Glen mansion
28 without a word. No greeting. No acknowledgment. No small talk. Without so much as looking
6
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COMPLAINT
1 at Plaintiff, he simply turned away from her after opening the door and walked upstairs. Plaintiff
2 hesitated but followed as she did not know what else to do or where else to go.
3 When they reached the bedroom, Sharpe pointed to the bed before disappearing into the
4 bathroom and shutting the door behind him. He still had not said a word. Plaintiff sat on the bed,
5 waiting, unsure of what to expect or if she should leave. Roughly five minutes later, he finally
6 emerged, but still, he said nothing. Instead, he turned off all the lights and laid down on his bed.
7 Plaintiff, uncomfortable and unsure of what to do, lay down as well. For roughly ten
8 minutes, there was nothing but silence. Then, without warning, Sharpe placed his hands on
9 Plaintiff’s neck from behind, pressed his erect penis against her body, and said his first words of
10 the night. “I knew from the first time I saw you that I was going to fuck you.” Doe and Sharpe
11 then engaged in oral sex. As they did so, Doe at some point realized Sharpe was using his phone.

12 He was apparently recording her. Plaintiff could see that he was trying to be discreet, but it was
13 obvious what he was doing. She said nothing, scared to confront him for what he might do or
14 say. When it ended, he rolled over and went to sleep. At some point later during the night, Sharpe
15 woke up, grabbed Plaintiff by her vagina, and began having sex with her.
16 The next morning, Sharpe woke at roughly 4 AM to shoot a media segment for sports
17 television. He woke Plaintiff as well and told her she needed to leave—but he informed her that

18 she had to be back by 9:00 PM, exactly.


19 The following night, Plaintiff arrived at Sharpe’s house at approximately 9:05 PM—just
20 five minutes past the time he had demanded. The moment he opened the door, Plaintiff
21 experienced his rage for the first time. Sharpe immediately launched into a verbal assault. He
22 screamed at Plaintiff, berating her for what felt like hours. He accused her of disrespecting him,
23 wasting his time, and warned that if she wanted to be with “The Shannon Sharpe,” she would
24 have to learn obedience. Plaintiff was terrified and feared for her physical safety. Still enraged,
25 Sharpe turned off the lights, grabbed her neck, and—just like the night before—began having
26 sexual intercourse with her. This cycle of control, fear, and submission became routine. Yelling
27 at her, controlling her, forcibly grabbing her by the neck when he got upset, saying he was going
28 to “kill her,” and asserting dominance became the norm.
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DELAHUNTY & EDELMAN LLP
CALIFORNIA
COMPLAINT
1 Over the next year and a half, Plaintiff saw Sharpe at his house as often as four times a
2 week. Sharpe continued to treat her like an object. He continued to control her—not just
3 physically, but emotionally and psychologically. He demanded complete control over her time
4 and body, expecting her to be at his house on his schedule, at his command, whenever he called.
5 The verbal abuse never stopped. He would berate and degrade Plaintiff, just as he had
6 from the beginning. One time specifically, he was yelling at her while there a was a firearm
7 visible in his room. Terrified for her safety, Plaintiff tried sharing her location with friends from
8 her iPhone—just in case. But Sharpe saw her doing this. The moment he realized what she was
9 doing, he grabbed her by the neck and told her “If you ever do that again, I will fucking kill you.”
10 D. Summer 2024: Sharpe’s Control Turns Abusive. The Relationship Becomes
11 Fearful and Non-Consensual.

12 Sharpe’s aggression and rage continued to escalate to the point that Plaintiff’s friends
13 began to fear for her safety. For example, when Plaintiff was with her friends, they could hear
14 Sharpe yelling at her over the phone, and would ask her if she was safe and if she was okay.
15 In the summer of 2024, Plaintiff and Sharpe each moved to Las Vegas for their own
16 reasons. Sharpe liked to say that the Plaintiff followed him to Vegas, but that too is a lie. Once
17 in Vegas, Sharpe again insisted that Plaintiff sign an NDA. She refused and again, he persisted.

18 But after enough resistance, he let it go and continued seeing her multiple times a week. His
19 behavior did not change—he remained erratic, controlling, and verbally abusive—all while
20 telling Plaintiff that he was committed to a sexually exclusive relationship with her.
21 Then, in September 2024, Sharpe humiliated Plaintiff. He livestreamed himself having
22 sex with another woman on Instagram—for over 1.1 million followers to see. He later made jest
23 of the incident on his podcast “Club Shay Shay” and show “Night Cap.” But for Plaintiff, it was
24 anything but funny. He had repeatedly assured her they were in an exclusive relationship (albeit
25 unhealthy and abusive). This was a lie that not only hurt her emotionally—it made her fear for
26 her sexual health and the risk of sexually transmitted disease.
27 At that point, Plaintiff began to pull away from Sharpe. She stopped answering his phone
28 calls and stopped telling him where she was when he would demand to know.
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COMPLAINT
1 Plaintiff’s feeble attempts at freedom and independence further upset Sharpe. He began
2 flooding her phone with calls, demanding to know where she was. He called relentlessly,
3 multiple times per hour. The harassment became so unbearable Plaintiff frequently began leaving
4 Nevada determined to cut off communication, resist his efforts to control her, and attempt to
5 reclaim some control of her life. It took courage for Plaintiff to make this effort. She remained
6 terrified even though she was thousands of miles away.
7 Sharpe simply would not accept independence or freedom for Plaintiff. In October 2024,
8 just after Plaintiff returned from Europe, Sharpe’s behavior became more angry, aggressive, and
9 now, violent.
10 E. October 6, 2024: Sharpe Sexually Assaults and Rapes Plaintiff, and
11 Threatens, "I’m going to make it so no man will want you again."

12 On October 6, 2024, Plaintiff was working out at a Nevada gym, following her usual
13 routine. As she worked out, she saw Sharpe aggressively approaching her. She could tell by his
14 look and the way he moved quickly towards her that he was furious for having been ignored. As
15 soon as he got close, he told her, “Sit the fuck down or I’m going to kill you.”
16 Plaintiff refused. “I don’t want to talk to you. You cheated on me.” His response was
17 dismissive and controlling as usual. “You don’t have a choice.”

18 Sharpe demanded that they talk in private. Again, Plaintiff told him no. She made it clear:
19 she did not want to talk to him, be alone with him, or want him coming to her home. But Sharpe
20 didn’t care. He never took no for an answer. Sharpe forced Plaintiff, under threat, to get into his
21 car, and go to her house.
22 Once Sharpe was inside her apartment, Plaintiff tried to keep the conversation in the
23 living room, but Sharpe refused. He demanded they go to the bedroom. She said no. He didn’t
24 listen, nor did he care. Once inside the bedroom, Sharpe grabbed her from behind and forcibly
25 positioned her to perform oral sex. He held her in place and then forced her to begin performing.
26 He became even angrier and said, “You’ve disrespected me so much. I’m going to punish this
27 asshole. I’m going to make it so no man will want you again.”
28 Plaintiff at this point was crying and sobbing. Tears streamed down her face as Sharpe
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COMPLAINT
1 repositioned her and took her from behind and inserted his penis into her anus. As he forcibly
2 anally raped her, he said, “Turn around and look at me.” Sharpe grabbed her head, forcing her
3 to look at him as she sobbed. He said at that point: “Look at this. Look at my arm. I’ve got chills.
4 That’s how good this is.”
5 Shannon Sharpe forced himself on the Plaintiff and raped her, despite her sobbing in
6 agony as it happened. He told her, in the moment as she was crying, that the experience was so
7 good it was giving him chills. Sharpe’s behavior demonstrates that he believed Plaintiff to be his
8 personal property, possessed and owned by him. He also believed that the laws did not apply to
9 him, that he could take what he wanted, and that no one could or would stop him. He was and is
10 wrong.
11 F. January, 2025: Sharpe Sexually Assaults and Rapes Plaintiff, Ignoring Her

12 Screams and Refusing to Wear a Condom.


13 On January 2, 2025, Sharpe told Plaintiff he wanted to see her. Sharpe persisted and
14 reminded Plaintiff that he had a combined Christmas and birthday gift to give to her, as he
15 previously promised her a gift. She ultimately allowed him to come over to her apartment. She
16 regrets that decision.
17 Once inside her apartment, Sharpe began undressing. Plaintiff firmly stated—multiple

18 times—that they would not have sex without protection, demanding that he wear a condom. She
19 knew that in the past he refused to ever use condoms, and believed that her demand would stop
20 him from having sex with her. But although he refused to use a condom, he still insisted on sex.
21 She tried to resist him. She screamed. She had already expressed concerns for her safety,
22 knowing that he had been involved with other women, increasing the risk of transmitting a
23 disease. The more she begged, Sharpe became more aggressive and made it clear, he would not
24 wear a condom and he was going to have his way with her.
25 Sharpe grabbed her—pulling her around and positioning her to perform oral sex, which
26 lasted for roughly two minutes. Then, Sharpe repositioned her and roughly forced himself inside
27 her. Plaintiff never stopped demanding and begging that he stop or put on a condom; Sharpe
28 ignored her.
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COMPLAINT
1 As soon as he penetrated her, Plaintiff screamed and sobbed. Her cries for help did
2 nothing to stop Sharpe.
3 The assault lasted roughly 10 minutes, ending only when Sharpe ejaculated inside
4 her. Plaintiff cried and begged repeatedly for him to stop. Plaintiff left Nevada after the assault.
5 Plaintiff brings these causes of action in this Honorable Court to recover damages as
6 outlined below. It is imperative that Shannon Sharpe and those like him are held accountable for
7 their actions to prevent them from engaging in further sexual assault and sodomy and harming
8 future victims.
9 V. FIRST CLAIM FOR RELIEF
10 A. ASSAULT, SEXUAL ASSAULT, BATTERY, & SEXUAL BATTERY
11 Plaintiff hereby incorporates each of the foregoing paragraphs as if fully set forth

12 herein.
13 As alleged herein, Defendant Sharpe willfully and unlawfully used threats and physical
14 force on Plaintiff.
15 In using willful and unlawful force on Plaintiff, Defendant Sharpe intended to cause a
16 harmful or offensive contact.
17 The threats were intended to control Plaintiff. The harmful and offensive contact intended

18 by Defendant Sharpe in fact occurred.


19 The threats, as well as the harmful and offensive contact by Defendant Sharpe caused
20 Plaintiff to suffer harm.
21 Sharpe’s conduct proximately caused injury to Plaintiff. Plaintiff has sustained and will
22 sustain pain and suffering, psychological and emotional distress, mental anguish,
23 embarrassment, and humiliation.
24 Accordingly, Plaintiff is entitled to recovery against Defendant for the damages
25 proximately caused by Defendant’s conduct in an amount to be determined at trial.
26 VI. SECOND CLAIM FOR RELIEF
27 B. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
28 Plaintiff re-alleges each aforementioned allegation as if fully incorporated below.
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COMPLAINT
1 Sharpe engaged in conduct that is extreme and outrageous so as to exceed the bounds of decency
2 in a civilized society. Namely, he caused Plaintiff to experience mental suffering by causing her
3 to worry about her safety and well-being. Time and time again, he reinforced that fear with verbal
4 threats.
5 Sharpe engaged in this conduct intentionally, knowingly, and willfully.
6 Sharpe’s conduct proximately caused injury to Plaintiff. Plaintiff has sustained and will
7 sustain pain and suffering, psychological and emotional distress, mental anguish,
8 embarrassment, and humiliation.
9 Accordingly, Plaintiff is entitled to recovery against Defendant for the damages
10 proximately caused by Defendant’s conduct in an amount to be determined at trial.
11 Thus, in addition to actual damages, Plaintiff seeks punitive damages, and such damages

12 are not subject to capping.


13 VII. DEMAND FOR JURY TRIAL
14 Plaintiff herein demands a jury trial and tenders all appropriate fees with this
15 Complaint.
16 VII. PRAYER FOR RELEIF
17 WHEREFORE, Plaintiff reserving the right to amend the Complaint prior to or during

18 the trial of this matter, prays judgment against Defendant as follows:


19 1. General damages in the sum in excess of $10,000,000;
20 2. Special damages in the sum in excess of $10,000,000;
21 3. Punitive damages in a sum in excess of $20,000,000;
22 4. Statutory penalties in a sum in excess of $10,000,000;
23 5. Declaration of rights as set forth above;
24 6. Attorneys’ fees and cost of litigation;
25 7. Interest at the statutory rate;
26 8. Such other and further relief the court deems reasonable under the premises.
27
[Signature on Following Page]
28
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COMPLAINT
1
2
3
Respectfully submitted,
4
DATED: April 20, 2025
5
DELAHUNTY & EDELMAN LLP
6
7 By: /s/ Micah Nash
8 Micah D. Nash
9 Nevada Bar No. 16596
[email protected]
10 DELAHUNTY & EDELMAN LLP
4 Embarcadero Center, Suite 1400
11 San Francisco, CA 94111
Telephone: 415-891-6210
12
Facsimile: 415-891-6256
13
14 THE BUZBEE LAW FIRM
15 Pro Hac Forthcoming
Anthony G. Buzbee
16 Texas Bar No. 24001820
[email protected]
17 Thomas Colby Holler
Texas Bar No. 24126898
18 [email protected]

19 J.P. Morgan Chase Tower


600 Travis, Suite 7500
20 Houston, Texas 77002
Telephone: (713) 223-5393
21 Facsimile: (713) 223-5909
www.txattorneys.com
22
Attorneys For Plaintiff Jane Doe
23
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28
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