Formation 8 Joe Lonsdale Lawsuit

Case3:15-cv-00382 Document1 Filed01/27/15 Page1 of 28
1 John C. Clune, Colorado Bar No. 27684

(pro hac vice motion forthcoming)
2 HUTCHINSON BLACK AND COOK, LLC
921 Walnut Street, Suite 200
3 Boulder, CO 80302
Telephone: (303) 442-6514
4 Fax: (303) 442-6593
E-Mail: [email protected]
5
L. Lin Wood, Georgia Bar No. 774588
6 (pro hac vice motion forthcoming)
David Ehrlich, Georgia Bar No. 353601
L. LIN WOOD, P.C.
8 1180 West Peachtree Street, Suite 2400
Atlanta, GA 30309
9 Telephone: (404) 891-1402
Fax: (404) 506-9111
10 E-Mail: [email protected]
11 Jennifer L. Liu, Cal. Bar No. 279370

THE LIU LAW FIRM, P.C.
12 324 Day Street
San Francisco, CA 94131
13 Telephone: (415) 896-4260
Fax: (415) 231-0011
15 Attorneys for Plaintiff Elise Clougherty
16
17
UNITED STATES DISTRICT COURT
18
NORTHERN DISTRICT OF CALIFORNIA
19
SAN FRANCISCO DIVISION
20
21
ELISE CLOUGHERTY,
22 Civil Action No.:
Plaintiff,
23
v. COMPLAINT FOR
24 DAMAGES
JOSEPH LONSDALE; FORMATION8
25 GP, LLC; and FORMATION8
PARTNERS, LLC; DEMAND FOR JURY TRIAL
26
Defendants.
27
28
COMPLAINT
2
Plaintiff Elise Marie Clougherty (“Ms. Clougherty” or “Plaintiff”) alleges as follows:
3
PRELIMINARY STATEMENT
4
1. This action arises out of a sexually, emotionally, and physically abusive
5
relationship between Stanford University mentor Mr. Joseph Lonsdale (“Mr. Lonsdale” or
6
“Defendant”), a successful and well-known Silicon Valley entrepreneur-turned-venture capitalist,
7
and Ms. Clougherty, which lasted from February 2012 to February 2013. At the time of the
8
events described in this Complaint, Ms. Clougherty was an undergraduate student at Stanford
9
University (“Stanford” or the “University”) and nearly ten years Mr. Lonsdale’s junior. During
10
the period in question, Mr. Lonsdale continuously and systematically subjected Ms. Clougherty to
11
repeated and incessant sexual assaults and abuse, employing psychological manipulation and
12
coercion in order to confuse, isolate, and otherwise disorient Ms. Clougherty from appreciating
13
the true danger of her situation.
14
2. In January 2012, Mr. Lonsdale used his participation in a technology
15
entrepreneurship mentor program at Stanford to hand-pick Ms. Clougherty to be his mentee.
16
Over the course of the next year, Mr. Lonsdale took advantage of his position of power and Ms.
17
Clougherty’s youth and trusting personality to draw her into a highly deviant, abusive, and
18
controlling relationship during which he perpetrated hundreds of non-consensual, and often
19
violent, sexual acts upon her.
20
3. During the summer of 2012, Mr. Lonsdale hired Ms. Clougherty to be an intern at
21
his technology venture capital firm, Formation8 GP, LLC and Formation8 Partners, LLC
22
(collectively, “Formation 8”). Mr. Lonsdale’s position of authority over Ms. Clougherty enabled
23
him to extend his control over her and to continue subjecting her to repeated, non-consensual
24
sexual acts.
25
4. In or around February 2013, Ms. Clougherty’s family began to suspect that
26
something was terribly wrong with her relationship with Mr. Lonsdale. They intervened and
27
helped her leave Mr. Lonsdale. Over the next couple of months, they discovered the true extent
28
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2
of the deviant and violent abuse she had endured as his supposed girlfriend over the previous
3
year.
4
5. In February 2013, Ms. Clougherty and her family reported Mr. Lonsdale’s actions
5
to Stanford University. Stanford retained an outside investigator to investigate her allegations.
6
At the conclusion of the investigation, the outside investigator found that Mr. Lonsdale had
7
engaged in conduct meeting the definitions of sexual harassment and sexual misconduct under
8
Stanford’s Title IX policy, and that it was “more likely than not that [Ms. Clougherty] expressed
9
to [Mr. Lonsdale] that she did not want to engage in the sexual conduct in question, but that [Mr.
10
Lonsdale did not comply with [her] request.” As a result of the investigation, Stanford banned
11
Mr. Lonsdale from Stanford’s campus for a minimum of ten years.
12
JURISDICTION
13
6. Ms. Clougherty is an adult female who resides in Vienna, Virginia.
14
7. Ms. Clougherty is a citizen of the Commonwealth of Virginia for purposes of
15
diversity jurisdiction under 28 U.S.C. § 1332 and was a Virginia citizen at all times pertinent and
16
relevant to the incidents described in this Complaint.
17
8. Upon information and belief, Mr. Lonsdale is an adult male who resides in San
18
Mateo County, in the State of California. Upon information and belief, Mr. Lonsdale is a citizen
19
of the State of California for purposes of diversity jurisdiction under 28 U.S.C. § 1332 and was a
20
California citizen at all times pertinent and relevant to the incidents described in this Complaint.
21
9. Formation8 GP, LLC is a limited liability corporation incorporated in Delaware,
22
with a principal place of business in San Francisco, California.
23
10. Formation8 Partners, LLC is a limited liability corporation incorporated in
24
Delaware, with a principal place of business in San Francisco, California.
25
11. This Court has original subject matter jurisdiction with respect to this action
26
pursuant to 28 U.S.C. § 1332, as there exists complete diversity of citizenship between Plaintiff
27
and Defendants, and the amount in controversy exceeds Seventy-Five Thousand Dollars
28
($75,000.00), exclusive of interest and costs.
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2
12. Defendants are subject to the jurisdiction of this Court pursuant to 28 U.S.C §
3
1332.
4
13. Mr. Lonsdale is subject to the personal jurisdiction of this Court as a citizen and
5
resident of California.
6
14. Formation8 GP, LLC and Formation8 Partners, LLC are subject to the personal
7
jurisdiction of this Court as their primary place of business is located in San Francisco, California.
8
VENUE
9
15. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) because
10
Defendants reside in this District and a substantial part of the events giving rise to the claims
11
occurred in this District.
12
16. Intradistrict Assignment: Pursuant to N.D. Cal. Local Rule 3-2(c) and (e),
13
intradistrict assignment to the San Francisco Division is proper because a substantial part of the
14
events that give rise to the claims asserted occurred in San Mateo County and Defendants reside
15
in San Mateo County.
16
THE PARTIES
17
Ms. Elise Clougherty
18
17. Ms. Clougherty is the 24 year-old daughter of Patrick and Anne Clougherty, and
19
the older sister to three brothers.
20
18. Ms. Clougherty was raised in Vienna, Virginia, a suburb of Washington, D.C.
21
19. Ms. Clougherty graduated from one of the nation’s most competitive high schools,
22
the Thomas Jefferson High School for Science and Technology, where she was one of very few
23
students to graduate with a straight-A average. In addition to succeeding academically, she was
24
also involved in music, was captain of the varsity lacrosse team, and was president of the
25
National Honor Society.
26
20. In addition to being extremely bright, Ms. Clougherty is also very beautiful. She
27
is slender, 5’10”, and has long, blonde hair and striking facial features. From approximately age
28
13 to 20, she worked for Ford Models as a print model.
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2
21. From a very young age, Ms. Clougherty’s appearance has drawn an inordinate
3
amount of unsolicited and often unwanted attention from male onlookers, acquaintances, and
4
friends. At or around age 10, for example, a male stranger tried to assault and abduct her when
5
she went to use the bathroom of a restaurant. Through adolescence, Ms. Clougherty continued to
6
experience constant attention from men, often in intimidating and frightening ways. Ms.
7
Clougherty’s parents went to great lengths to shield her from this attention; for example, Ms.
8
Clougherty’s mother escorted her on almost every modeling trip Ms. Clougherty took.
9
22. Ms. Clougherty also comes from a Catholic family and has always been committed
10
to her faith. Prior to meeting Mr. Lonsdale, Ms. Clougherty was a virgin.
11
Mr. Joseph Lonsdale
12
23. Mr. Lonsdale is a successful and widely-known entrepreneur involved in
13
numerous business ventures and entities.
14
24. He is a 2003 graduate of Stanford University. While at Stanford, he served as the
15
Editor-in-Chief of the Stanford Review, Stanford’s conservative/libertarian newspaper.
16
25. In 2004, Mr. Lonsdale co-founded Palantir Technologies, a multi-billion dollar
17
data-mining software company. Mr. Lonsdale has been involved in numerous other successful
18
Internet startups, including PayPal, and has also worked for Clarium Capital, a global macro
19
hedge fund.
20
26. In 2009, Mr. Lonsdale founded Addepar, Inc. (“Addepar”), a leader in private
21
wealth management technology. Upon information and belief, Mr. Lonsdale currently serves as
22
the Chairman of Addepar.
23
27. Mr. Lonsdale is also a founding partner at Formation 8, a technology venture
24
capital fund.
25
28. At all times relevant to the events described in this Complaint, Mr. Lonsdale was
26
an agent of Formation 8.
27
29. Mr. Lonsdale has also served as the founding Chairman of The Seasteading
28
Institute, a non-profit dedicated to creating “floating cities” on the open seas, with independent,
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“highly autonomous” governments where residents and entrepreneurs can be “free to operate their
3
own lives and businesses.”
4
Formation 8
5
30. Formation 8 is a technology venture capital fund founded in 2011. Formation 8’s
6
headquarters are located in San Francisco, California.
7
INTIMATE PARTNER VIOLENCE
8
Intimate Partner Violence in the United States
9
31. Intimate partner violence in the United States is a national epidemic. According to
10
statistics collected by the Centers for Disease Control and Prevention, more than one in three
11
women (35.6%) in the United States has experienced rape, physical violence, and/or stalking by
12
an intimate partner at some point in her life, and nearly one in five (18.3%) has been raped.1
13
More than half of all female rape victims (51.1%) report being raped by an intimate partner, as
14
opposed to an acquaintance or stranger.2 An estimated 9.4% of all women in the United States
15
have been raped by an intimate partner at some point in their lives.3 On average, more than three
16
women a day are murdered by their husbands or boyfriends in the United States.4
17
32. This epidemic is particularly acute among college-age women. While women of
18
all ages are at risk for domestic and sexual violence, those ages 20 to 24 are at the greatest risk of
19
experiencing nonfatal intimate partner violence.5 One in five women is sexually assaulted in
20
college.6
21
33. Intimate partner violence is also a silent epidemic. Intimate partner violence is one
22
of the most chronically underreported crimes. Studies have estimated that between 64% and 96%
23
1
24 Black, M.C., Basile, K.C., Breiding, M.J., Smith, S.G., Walters, M.L., Merrick, M.T., Chen, J.,
& Stevens, M.R. (2011). The National Intimate Partner and Sexual Violence Survey (NISVS):
25 2010 Summary Report. Atlanta, GA: National Center for Injury Prevention and Control, Centers
for Disease Control and Prevention. Retrieved from:
26 http://www.cdc.gov/violenceprevention/pdf/nisvs_executive_summary-a.pdf.
2
Id.
3
27 Id.
4
Catalano, Shannan. 2007. Intimate Partner Violence in the United States. U.S. Department of
28 Justice, Bureau of Justice Statistics. Available at
http://bjs.ojp.usdoj.gov/content/pub/pdf/ipvus.pdf.
5
Id.
6
http://www.futureswithoutviolence.org/resources-events/get-the-facts/#fn2.
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of all rapes are never reported to criminal justice authorities.7 Only a small minority of reported
3
cases, especially non-stranger assaults, ever result in the successful prosecution of the offender.8
4
34. Intimate partner violence is a costly epidemic. The costs of intimate partner
5
violence against women exceed an estimated $5.8 billion.9 These costs include nearly $4.1
6
billion in the direct costs of medical care and mental health treatment and nearly $1.8 billion in
7
the indirect costs of lost productivity and present value of lifetime earnings.10 Victims of rape
8
and sexual assault are 3 times more likely to suffer from depression, 6 times more likely to suffer
9
from post-traumatic stress disorder, and 4 times more likely to contemplate suicide.11 Sexual
10
violence victims exhibit a variety of psychological symptoms that are similar to those of victims
11
of other types of trauma, such as war and natural disaster.12
12
The Pathology of Abusers
13
35. The research on sexual violence clearly demonstrates that a vastly disproportionate
14
number of rapes and sexual assaults are committed by a small percentage of the male
15
population—serial sexual predators.13 In one study, the average number of victims for each
16
predator was seven; in another study, it was eleven.14
17
36. Social scientists now understand that sexual predators are not driven primarily by
18
sexual desire.15 Rather, they tend to be driven by a need to dominate or control their victims,
19
and/or resentment of and a general hostility against women.16 A smaller number of sexual
20
21
22 7
Lisak, David & Paul M. Miller, Repeat Rape and Multiple Offending Among Undetected
23 Rapists, Violence & Victims, Vo. 7, No. 1, 2002, p. 1.
8
Id.
9
24 National Center for Injury Prevention and Control. Costs of Intimate Partner Violence Against
Women in the United States. Atlanta (GA): Centers for Disease Control and Prevention; 2003.
10
25 Id.
11
National Research Council. (1996). Understanding Violence Against Women. Washington,
26 DC: National Academy Press.
12
Id.
13
27 Harwell, Claire M. & David Lisak, Why Rapists Run Free, Sexual Assault Report, No. 14, No.
2, Nov./Dec. 2010, p. 17.
14
28 Lisak, David, Understanding the Predatory Nature of Sexual Violence, Sexual Assault Report,
Vol. 14, No. 4, March/April 2011, p. 55.
15
Id.
16
Id.
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predators are driven by the sexual gratification they experience by inflicting pain on their
3
victims.17
4
37. The vast majority of sexual predators go unpunished. Factoring in unreported
5
rapes, only an estimated 3% of rapists will ever spend a day in jail.18 The other 97% will walk
6
free, receiving no punishment.19
7
38. Undetected sexual predators tend to share a common modus operandi.20 By
8
targeting non-strangers and refraining from unnecessary violence, these sexual predators have
9
largely escaped prosecution.21 Sexual predators who succeed at evading detection are extremely
10
adept at identifying suitable victims and testing prospective victims’ boundaries; they plan and
11
premeditate their attacks, using sophisticated strategies to groom their victims for attack and to
12
isolate them physically; they use violence instrumentally—that is, they use only as much violence
13
as is needed to terrify and coerce their victims into submission; and they use psychological
14
weapons—power, control, manipulation, and threats—to control their victims.22
15
STATEMENT OF FACTS
16
Ms. Clougherty’s Early Life at Stanford
17
39. In the fall of 2009, Ms. Clougherty began her freshman year at Stanford. Although
18
she intended to study neuroscience, she immediately became interested in technology
19
entrepreneurship after a freshman year class on internet start-ups.
20
40. Ms. Clougherty was thrilled to be part of the Stanford community and enjoyed
21
student life at Stanford immensely. However, from very early on, she began experiencing
22
negative unwanted male attention, including stalking and verbal assaults. Ms. Clougherty and her
23
mother reported two particularly threatening incidents to Stanford authorities.
24
25
26 17
Id.
18
27 https://rainn.org/news-room/97-of-every-100-rapists-receive-no-punishment.
19
Id.
20
28 Lisak, David, Understanding the Predatory Nature of Sexual Violence, Sexual Assault Report,
Vol. 14, No. 4, March/April 2011, p. 56.
21
Id.
22
Id.
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41. These early problems with stalking and harassment led Ms. Clougherty to feel
3
extremely anxious and unsafe. In the fall of 2010, after she learned that she had been placed in
4
the same residential hall as one of the male students she had reported for harassment, she began to
5
feel increasingly fearful and anxious. This anxiety triggered Ms. Clougherty to develop an eating
6
disorder, which required her to take several months off of school to receive full-time treatment.
7
After several months, Ms. Clougherty returned to Stanford to resume her studies in the spring
8
quarter of 2011.
9
Mr. Lonsdale’s First Interactions with Ms. Clougherty
10
42. In the winter of 2010-11, a mutual acquaintance of Ms. Clougherty’s and Mr.
11
Lonsdale’s introduced them over email. Because of Ms. Clougherty’s interest in technology
12
entrepreneurship, she was interested in meeting Mr. Lonsdale and emailed him to meet. In or
13
around January 2011, when Ms. Clougherty was 20 years old, they met at a bar in New York
14
City. The meeting was extremely brief, lasting approximately fifteen or twenty minutes, during
15
which Mr. Lonsdale paid little attention to Ms. Clougherty.
16
43. Ms. Clougherty next ran into Mr. Lonsdale in Palo Alto in the spring of 2011, after
17
which Ms. Clougherty and Mr. Lonsdale began corresponding over email about technology
18
entrepreneurship and Internet start-ups. In October 2011, Ms. Clougherty and Mr. Lonsdale met
19
again at a bar in Palo Alto. The meeting was brief and ended in Mr. Lonsdale stroking Ms.
20
Clougherty’s face and hair and leaning in as if he were going to kiss her, and Ms. Clougherty
21
getting up to walk away.
22
44. In January 2012, Mr. Lonsdale discovered that Ms. Clougherty was enrolled in a
23
class called High Technology Entrepreneurship—a class in which Mr. Lonsdale had volunteered
24
to serve as a mentor. Although Ms. Clougherty had already been assigned two mentors, Mr.
25
Lonsdale leveraged his friendship with the professor teaching the class and his influence as a
26
prominent Stanford alumnus to arrange for the professor to reassign Ms. Clougherty as Mr.
27
Lonsdale’s mentee. Mr. Lonsdale later told Ms. Clougherty that after he asked the professor to
28
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reassign her to him, the professor told Mr. Lonsdale that Mr. Lonsdale “knew how to pick out the
3
pretty ones.”
4
45. On or around January 24, 2012, Ms. Clougherty went to meet Mr. Lonsdale at his
5
Addepar office for their first mentor/mentee meeting. When Ms. Clougherty got to his office, she
6
saw that he had a photograph of a half-naked woman prominently displayed on his computer
7
screen. During their conversation, Mr. Lonsdale asked Ms. Clougherty if she knew the woman,
8
alluding to the fact that Ms. Clougherty had been a model.
9
46. At their second mentor/mentee meeting, on or about February 3, 2014, Ms.
10
Clougherty and one of her co-mentees met with Mr. Lonsdale at Addepar. Mr. Lonsdale asked
11
for Ms. Clougherty’s co-mentee to leave early so that he could meet with Ms. Clougherty alone.
12
He then drove her to the Four Seasons Hotel in Palo Alto, where they sat at the bar. Mr. Lonsdale
13
offered her alcohol—which she refused. While at the bar, Mr. Lonsdale talked about
14
inappropriate sexual topics, including how he had had uncontrollable sexual urges when he was
15
younger. He then drove her back to and dropped her off at her dorm.
16
Mr. Lonsdale’s Early Abuse of Ms. Clougherty
17
47. In or around February 2012, Mr. Lonsdale used his position of power as Ms.
18
Clougherty’s mentor to initiate an intimate relationship with Ms. Clougherty. On the night of
19
their first sexual encounter, Ms. Clougherty believed that Mr. Lonsdale was picking her up from
20
campus to go to dinner in Palo Alto to discuss her team’s project. Instead, Mr. Lonsdale drove
21
her back to his home in Los Altos Hills. Shortly after arriving at his house, he started to kiss her
22
aggressively and to try to take off her pants. Despite Ms. Clougherty trying to avoid him and
23
pushing his hands away from her crotch at least a half dozen times, Mr. Lonsdale persisted. Mr.
24
Lonsdale then pulled Ms. Clougherty into a bedroom where he took off her clothes and his pants,
25
and began to penetrate her with his flaccid penis. During this episode, Mr. Lonsdale acted as
26
though he were not doing anything wrong and made comments insinuating that Ms. Clougherty
27
had wanted the sexual contact.
28
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48. In the days after their first sexual encounter, Mr. Lonsdale showered Ms.
3
Clougherty with gifts and attention: profusely telling her about his feelings for her, talking about
4
how they would be a “power couple,” sending her large, expensive flower arrangements and
5
buying her other gifts, and calling her frequently. In the following weeks, Mr. Lonsdale
6
repeatedly continued to force Ms. Clougherty to have sexual contact with him without her
7
consent. From very early on, Mr. Lonsdale repeatedly told Ms. Clougherty that it was women’s
8
nature to enjoy being raped, especially if they are raped by a man with greater means.
9
49. During this period, Ms. Clougherty began to feel depressed. She started crying
10
frequently and began to withdraw from her friends. In March, her roommate abruptly moved out
11
of their dorm room. The roommate later told Ms. Clougherty that she had wanted to move out
12
because Ms. Clougherty was giving off “too much negative energy.” Around the same time, a
13
male classmate who Ms. Clougherty had been dating also stopped seeing her. Socially isolated,
14
Ms. Clougherty grew increasingly attached to her abuser and became psychologically trapped, in
15
that she believed she could not leave the relationship and did not understand that her thoughts and
16
feelings were caused by fear and trauma.
17
50. In March 2012, knowing that Ms. Clougherty had plans to visit her family in Spain
18
later than month, Mr. Lonsdale invited Ms. Clougherty to join him for several days in London and
19
Rome. Before the trip, Mr. Lonsdale told Ms. Clougherty that he had booked two hotel rooms –
20
one for him, and one for her. When Ms. Clougherty arrived in London to meet him, she
21
discovered that he had booked only one room. In London, Mr. Lonsdale continued to force her to
22
have sexual contact with him without her consent. Throughout the trip, Mr. Lonsdale deprived
23
her of both food and sleep by scheduling late night and early morning activities, delaying meals,
24
not ordering her enough food, and other such tactics.
25
51. On the last evening of the trip, in Rome, Mr. Lonsdale forcibly raped Ms.
26
Clougherty. In their hotel room, Mr. Lonsdale penetrated her with several fingers, and then
27
abruptly started penetrating her with his erect penis. She immediately pulled away from him. He
28
then grabbed her and penetrated her again. She immediately pulled away a second time and ran
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into the bathroom, where she locked the door and cried for several hours. The following day, Ms.
3
Clougherty flew to Spain to meet her mother and brother. When her mother picked her up from
4
the airport, Ms. Clougherty was exhausted and extremely disoriented. Ms. Clougherty then slept
5
for almost 23 hours.
6
52. Over the next several months, Ms. Clougherty continued to see Mr. Lonsdale. To
7
control Ms. Clougherty, Mr. Lonsdale employed many forms of psychological manipulation and
8
control on her, including but not limited to “positive intermittent reinforcement,” “gaslighting,”
9
isolation, sleep deprivation, food deprivation, anger, embarrassment, and guilt. Typically, Mr.
10
Lonsdale would arrange to visit Ms. Clougherty in her dorm room or would pick her up and take
11
her back to his house or to a hotel, sometimes for the entire weekend. Mr. Lonsdale also took Ms.
12
Clougherty on several trips. During these times together, Mr. Lonsdale kept Ms. Clougherty
13
isolated from others and repeatedly forced himself on her without her consent.
14
53. On countless occasions during this period, Ms. Clougherty told Mr. Lonsdale that
15
she did not want to have sex and asked him not to penetrate her. Mr. Lonsdale dismissed her
16
protests and continued to coerce her to engage in sex with him. Throughout this period, Mr.
17
Lonsdale repeatedly commented to Ms. Clougherty that women needed to be raped to learn to be
18
loyal and that they really enjoyed being raped more than they let on.
19
Mr. Lonsdale Hires Ms. Clougherty To Work as an Intern
20
54. In or around May 2012, Mr. Lonsdale suggested that Ms. Clougherty work for him
21
over the summer at his venture capital fund, Formation 8. From late June 2012 to early August
22
2012, a period of roughly six weeks, Ms. Clougherty worked as an intern for Mr. Lonsdale and
23
Formation 8.
24
55. The primary project to which Mr. Lonsdale assigned Ms. Clougherty was to
25
construct a web-based survey on emerging technologies based on interviews with various leaders
26
in finance, entrepreneurship, and academia. During her internship at Formation 8, Mr. Lonsdale
27
directly supervised Ms. Clougherty, set her rate of pay, gave her work assignments, reviewed her
28
work, and told her with whom she should meet. Mr. Lonsdale also coordinated a work-related
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2
trip to New York with Ms. Clougherty during her internship so that he would have greater access
3
to her.
4
56. During the period of the internship, including on the work-related trip to New
5
York, Mr. Lonsdale continued to use his increasing influence and power over Ms. Clougherty to
6
repeatedly, regularly, and continuously force himself upon her sexually without her consent.
7
Mr. Lonsdale Escalates His Sexual Deviance and Violence Against, and Control Over, Ms.
8
Clougherty
9
57. Throughout the summer of 2012, Mr. Lonsdale increasingly began exhibiting
10
violent and deviant behaviors during his sexual assaults of Ms. Clougherty. During intercourse,
11
he would regularly shake Ms. Clougherty violently and would not stop, despite her protests, until
12
she promised she would always “listen to her master.” In addition to shaking her violently during
13
sexual assaults, he also began strangling her, slapping her, scratching her, yanking her by the hair
14
so hard that he would lift her torso off the bed, and slamming her body against the walls and
15
bedboards. He would growl and yell derogatory comments at her. He frequently covered her
16
face with a pillow or pushed her face to the side so that she could not look at him. Mr. Lonsdale
17
also often treated Ms. Clougherty’s body like an object—for example, grabbing her head and
18
using it to push open a shower door.
19
58. Mr. Lonsdale typically forced Ms. Clougherty to have sex several times a day—on
20
some occasions, as many as ten or more times a day. When Ms. Clougherty was on her period,
21
Mr. Lonsdale’s attacks were especially frequent. He often would not let her buy tampons and
22
seemed to relish getting her blood everywhere—on her clothing, bed sheets, hotel furniture, car
23
and bus seats, and elsewhere. He would not let her clean up the blood, and would get very angry
24
with her if she tried to clean it up. On one occasion, in a hotel room, he even picked up her naked
25
body and made her sit on the hotel furniture so as to smear her blood all over it.
26
59. Between approximately late summer 2012 and the end of their relationship, in
27
February 2013, Ms. Clougherty confronted Mr. Lonsdale about his sexual abuse on multiple
28
occasions. She repeated her earlier statements that she did not wish to have a sexual relationship
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2
with him and that she believed he was abusing and raping her, and she pleaded with him to stop
3
his behavior. At some point, she even began calling him the “raping ape man” to his face. In
4
many of these confrontations, Mr. Lonsdale reacted with such anger that Ms. Clougherty became
5
too afraid to continue protesting. On several occasions he admitted that he was abusing her, but
6
claimed that he had a sickness, that he could not control himself, and that he needed her help to
7
change. After months of seemingly kind and loving behavior from Mr. Lonsdale interspersed
8
with the abuse, Ms. Clougherty felt powerfully attached to Mr. Lonsdale and believed that if she
9
was more supportive and treated him with kindness, he would stop hurting her. She wrote him
10
numerous emails and love letters to let him know how much she cared about him in the hope that
11
it would end the abuse.
12
60. However, in or around February 2013, Mr. Lonsdale’s assaults began to grow even
13
more deviant and violent. At one point, he told Ms. Clougherty that he had only done “10%” of
14
what he wanted to do to her, that he planned to take the entire month of April off to explore the
15
depths of his sexual deviancy, and that if she didn’t stop protesting, he would have to find a new
16
victim.
17
Ms. Clougherty’s Family Intervenes
18
61. In or around February 2013, Ms. Clougherty had a severe emotional breakdown
19
and called her mother. Fearing that Ms. Clougherty was suicidal, Ms. Clougherty’s mother flew
20
to Stanford to see her daughter.
21
62. When Ms. Clougherty’s mother saw Ms. Clougherty in person, she was horrified
22
by her daughter’s physical appearance and condition. Ms. Clougherty had lost significant weight,
23
her face was bloated, and she had cysts on the back of her neck and torso where Mr. Lonsdale had
24
recently dug his nails into her flesh during a sexual assault. Ms. Clougherty’s mother and one of
25
Ms. Clougherty’s friends then helped Ms. Clougherty devise a plan to leave Mr. Lonsdale.
26
63. On February 22, 2013, Ms. Clougherty arranged to meet Mr. Lonsdale at a public
27
park. She confronted him again on the fact that he had raped her hundreds of times over the past
28
- 13 - COMPLAINT
2
year. He became very angry and admitted that he had, but said that what he had done to her was
3
only rape because her “Catholic guilt” told her she was not supposed to have sex.
4
The Stanford Investigation and Findings
5
64. In February 2013, Ms. Clougherty and her mother contacted Stanford officials to
6
report Mr. Lonsdale’s actions to them. Stanford retained an outside investigator to investigate
7
Ms. Clougherty’s allegations. At the end of the investigation, the outside investigator concluded
8
that Mr. Lonsdale had engaged in conduct meeting the definitions of sexual harassment and
9
sexual misconduct under Stanford’s Title IX policy, and that it was “more likely than not that
10
[Ms. Clougherty] expressed to [Mr. Lonsdale] that she did not want to engage in the sexual
11
conduct in question, but that [Mr. Lonsdale] did not comply with [her] request.” As a result of
12
the investigation, Stanford banned Mr. Lonsdale from Stanford’s campus for a minimum of ten
13
years. Stanford’s determination further states that Mr. Lonsdale may request that the restriction
14
be lifted at the end of the ten year period, but that “he has been strongly encouraged to be
15
prepared to justify lifting the restriction by demonstrating that he has sought counseling, training,
16
or other education with respect to sexual misconduct and relationship violence.”
17
Ms. Clougherty’s Trauma and Recovery
18
65. As a result of the trauma Ms. Clougherty experienced at the hands of Mr.
19
Lonsdale, she began experiencing debilitating symptoms of post-traumatic stress disorder
20
(“PTSD”). After Ms. Clougherty left Mr. Lonsdale, she could not be alone and suffered from
21
night terrors and flashbacks that caused her to weep and scream uncontrollably for hours. She felt
22
depressed and had suicidal thoughts. She experienced twitching and convulsions. She could not
23
leave the house or drive by herself or engage in normal everyday activities.
24
66. In March 2013, Ms. Clougherty took a doctor-prescribed medical leave from
25
Stanford in order to return home, where she could begin receiving full-time treatment. On March
26
27, 2013, Ms. Clougherty was evaluated by Elna Yadin, Ph.D., at Bryn Mawr College, one of the
27
nation’s foremost experts on PTSD. Dr. Yadin diagnosed Ms. Clougherty with PTSD. She then
28
- 14 - COMPLAINT
2
underwent treatment for PTSD with Dr. Keith E. Saylor, Ph.D, Sc.M., a renowned clinical
3
psychologist.
4
67. Stanford accommodated Ms. Clougherty’s need for medical leave, allowing her to
5
finish school from home. Despite the debilitating symptoms she was suffering during this period,
6
she was able to graduate on time, in June 2013, with her Bachelor of Science.
7
68. Although Ms. Clougherty has made great strides in her recovery, she continues to
8
suffer to this day from a number of serious injuries including, but not limited to, debilitating
9
flashbacks, emotional breakdowns, and periods of severe depression.
10
COUNT I – SEXUAL BATTERY
11 AGAINST JOSEPH LONSDALE
12 Cal. Civ. Code § 1708.5
13 69. Ms. Clougherty incorporates by reference all prior allegations in this Complaint as
14 if fully restated herein.
15 70. California Civil Code § 1708.5 provides that a person commits sexual battery on
16 another when that person:
17 (1) Acts with the intent to cause a harmful or offensive contact with an intimate part of
18 another, and a sexually offensive contact with that person directly or indirectly results.
19 (2) Acts with the intent to cause a harmful or offensive contact with another by use of his
20 or her intimate part, and a sexually offensive contact with that person directly or indirectly
21 results.
22 (3) Acts to cause an imminent apprehension of the conduct described in paragraph (1) or
23 (2), and a sexually offensive contact with that person directly or indirectly results.
24 71. Mr. Lonsdale engaged in sexual battery of Ms. Clougherty’s person with the intent
25 to cause harmful and offensive contact with intimate parts of her body. As set forth above, Mr.
26 Lonsdale intentionally acted to cause a harmful and offensive contact to Ms. Clougherty’s
27 intimate parts when Mr. Lonsdale, among other intentional acts, repeatedly touched the private
28 parts of Ms. Clougherty without her consent and repeatedly engaged in non-consensual sexual
intercourse, doing so continuously and incessantly between February 2012 and February 2013.
- 15 - COMPLAINT
2
72. Mr. Lonsdale engaged in sexual battery on Ms. Clougherty’s person with the intent
3
to cause harmful and offensive contact by use of his own intimate parts. As set forth above, Mr.
4
Lonsdale engaged in intentional harmful and offensive contact of Ms. Clougherty’s person by,
5
among other intentional acts, rubbing his sexual organs against her and penetrating her with his
6
sexual organ on hundreds of occasions without her consent, doing so continuously and
7
incessantly between February 2012 and February 2013.
8
73. Mr. Lonsdale engaged in sexual battery of Ms. Clougherty by placing her in fear
9
of imminent harmful and offensive contact, with such harmful and offensive contact in fact
10
resulting immediately thereafter.
11
74. As a direct and proximate result of Mr. Lonsdale’s tortious, wrongful, and
12
unlawful acts and conduct towards her, Ms. Clougherty has suffered past and future special
13
damages and past and future general damages in an amount to be proven at trial, but not less than
14
$75,000. Ms. Clougherty has been damaged and injured physically, emotionally, and financially,
15
including but not limited to suffering from pain, anxiety, depression, severe emotional distress,
16
embarrassment, ridicule, and PTSD, as well as loss of health, future relationships, income,
17
employment, and future career benefits and earning potential.
18
75. In engaging in the conduct herein alleged, Mr. Lonsdale acted with malice, fraud,
19
and oppression and in conscious disregard of Ms. Clougherty’s health, rights, dignity and well-
20
being, and intended to subject Ms. Clougherty to unjust hardship and mental anguish, thereby
21
warranting an assessment of punitive damages in an amount sufficient to punish Mr. Lonsdale
22
and deter others from engaging in similar conduct.
23
COUNT II – SEXUAL ASSAULT
27 77. As set forth above, Mr. Lonsdale engaged in sexual assault on Ms. Clougherty’s
28 person with the intent to cause harmful and offensive contact when he placed Ms. Clougherty in
- 16 - COMPLAINT
2
imminent fear of such a harmful or physical contact without her consent, doing so continuously
3
and incessantly between February 2012 and February 2013.
4
5
6
7
8
9
10
11
12
13
14
15
16
COUNT III – DOMESTIC VIOLENCE
18 Cal. Civ. Code § 1708.6
21 81. California Civil Code § 1708.6(a) states that “a person is liable for the tort of
22 domestic violence if the plaintiff proves the following elements:
23 (1) The infliction of injury upon the plaintiff resulting from abuse, as defined in
24 subdivision (a) of Section 13700 of the Penal Code.
25 (2) The abuse was committed by the defendant, a person having a relationship with the
26 plaintiff as defined in subdivision (b) of Section 13700 of the Penal Code.”
27 82. During the time in question, Ms. Clougherty and Mr. Lonsdale had a “dating
28 relationship” for purposes of Cal. Civ. Code § 13700(b). This “dating relationship” began in
February 2012 and ended in February of 2013.
- 17 - COMPLAINT
2
83. During this relationship, Mr. Lonsdale, as set forth above, repeatedly engaged in
3
abuse as defined by Cal. Civ. Code § 13700(b), to wit, intentionally or recklessly causing or
4
attempting to cause bodily injury to Ms. Clougherty and placing her in reasonable apprehension
5
of imminent serious bodily injury to herself, doing so continuously and incessantly between
6
February 2012 and February 2013.
7
8
9
10
11
12
13
14
15
16
17
18
19
86. Ms. Clougherty is also entitled to an award of costs and attorneys’ fees against Mr.
20
Lonsdale pursuant to California Civil Code § 1708.6.
21
COUNT IV – GENDER VIOLENCE
23 Cal. Civ. Code § 52.4
26 88. California Civil Code § 52.4 states that gender violence is “a form of sex
27 discrimination” and includes:
28 (1) One or more acts that would constitute a criminal offense under state law that has as an
element the use, attempted use, or threatened use of physical force against the person or
- 18 - COMPLAINT
2
property of another, committed at least in part based on the gender of the victim, whether
3
or not those acts have resulted in criminal complaints, charges, prosecution, or conviction.
4
(2) A physical intrusion or physical invasion of a sexual nature under coercive conditions,
5
whether or not those acts have resulted in criminal complaints, charges, prosecution, or
6
conviction.
7
89. As set forth above, Mr. Lonsdale wrongfully, intentionally, and tortiously deprived
8
Ms. Clougherty of her right to be free from any use of physical force, violence, or intimidation by
9
threat of violence or use of physical force, committed against her person because of her sex
10
and/or gender, doing so continuously and incessantly between February 2012 and February 2013.
11
90. Upon information and belief, Ms. Clougherty’s gender was a motivating factor in
12
Mr. Lonsdale’s unlawful treatment of her and Mr. Lonsdale’s unlawful acts were committed at
13
least in part based on Ms. Clougherty’s gender.
14
15
16
17
18
19
20
21
22
23
24
25
26
93. Ms. Clougherty is also entitled to an award of costs and attorneys’ fees against Mr.
27
Lonsdale pursuant to California Civil Code § 52.4.
28
- 19 - COMPLAINT
2 COUNT V – SEXUAL HARASSMENT

AGAINST JOSEPH LONSDALE
3
Cal. Civ. Code § 51.9
4
94. Ms. Clougherty incorporates by reference all prior allegations in this Complaint as
5
if fully restated herein.
6
95. California Civil Code § 51.9 states:
7
(a) A person is liable in a cause of action for sexual harassment under this section
8
when the plaintiff proves all of the following elements:
9
(1) There is a business, service or professional relationship between the plaintiff
10
and defendant. Such a relationship may exist between a plaintiff and a person,
11
including, but not limited to, any of the following persons: . . .
12
(E) Teacher
13
(F) A relationship that is substantially similar to any of the above.
14
(2) The defendant has made sexual advances, solicitations, sexual requests,
15
demands for sexual compliance by the plaintiff, or engaged in other verbal, visual,
16
or physical conduct of a sexual nature or of a hostile nature based on gender, that
17
were unwelcome and pervasive or severe.
18
(3) There is an inability by the plaintiff to easily terminate the relationship.
19
(4) The plaintiff has suffered or will suffer economic loss or disadvantage or
20
personal injury, including, but not limited to, emotional distress or the violation of
21
a statutory or constitutional right, as a result of the conduct described in paragraph
22
(2).
23
96. During the relevant time period, a school-sanctioned and arranged mentor/mentee
24
relationship existed between Mr. Lonsdale and Ms. Clougherty, a relationship substantially
25
similar to that of a teacher/student. Among other duties, Mr. Lonsdale was responsible for
26
instructional duties as a well as for evaluating Ms. Clougherty’s work for purposes of receiving
27
class credit.
28
- 20 - COMPLAINT
2
97. Additionally, during the summer of 2012, an employer/intern relationship existed
3
between Mr. Lonsdale and Ms. Clougherty while she interned at Formation 8. This relationship
4
constituted a business, service, or professional relationship under California Civil Code § 51.9, in
5
addition to the already existing mentor/mentee relationship.
6
98. During the relevant time period, Mr. Lonsdale frequently and incessantly made
7
unwanted sexual advances to Ms. Clougherty. He made sexual advances, solicitations, sexual
8
requests of her against her will and frequently sexually assaulted her despite her protests and
9
attempts to resist.
10
99. Mr. Lonsdale engaged in verbal and physical conduct of a sexual and hostile
11
nature towards Ms. Clougherty based at least in part on her gender, all of which were unwelcome,
12
pervasive, and severe.
13
100. There was an inability on Ms. Clougherty’s part to easily terminate the
14
relationship: Mr. Lonsdale was at various points during their relationship her assigned class
15
mentor and her employer. She was also unable to easily terminate the relationship because of the
16
severe trauma she experienced from Mr. Lonsdale’s repeated sexual assaults and his use of
17
psychological manipulation techniques.
18
19
20
21
22
23
24
25
26
27
28
- 21 - COMPLAINT
2
3
4
103. Ms. Clougherty is also entitled to an award of attorneys’ fees against Mr. Lonsdale
5
pursuant to California Civil Code § 52.
6
COUNT VI – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
10 105. Mr. Lonsdale’s conduct and actions towards Ms. Clougherty, as set forth above,
11 were extreme and outrageous and beyond the bounds of decency tolerated in a civilized society.
12 106. Mr. Lonsdale’s conduct and actions towards Ms. Clougherty were intended to
13 cause her emotional distress, and Mr. Lonsdale acted with reckless disregard to the probability
14 that Ms. Clougherty would suffer emotional distress.
15 107. Ms. Clougherty has suffered, and continues to suffer, extreme emotional distress
16 as a direct and proximate result of Mr. Lonsdale’s actions towards her, including but not limited
17 to the repeated, incessant, and continual acts of sexual assault abuse as previously set forth.
18 108. Mr. Lonsdale’s intentional actions were a substantial factor in causing Ms.
19 Clougherty’s severe emotional distress.
20 109. As a direct and proximate result of Mr. Lonsdale’s tortious, wrongful, and
21 unlawful acts and conduct towards her, Ms. Clougherty has suffered past and future special
22 damages and past and future general damages in an amount to be proven at trial, but not less than
23 $75,000. Ms. Clougherty has been damaged and injured physically, emotionally, and financially,
24 including but not limited to suffering from pain, anxiety, depression, severe emotional distress,
25 embarrassment, ridicule, PTSD, as well as loss of health, future relationships, income,
26 employment, and future career benefits and earning potential.
27 110. In engaging in the conduct herein alleged, Mr. Lonsdale acted with malice, fraud,
28 and oppression and in conscious disregard of Ms. Clougherty’s health, rights, dignity and well-
- 22 - COMPLAINT
2
3
4
COUNT VII – NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
8 112. Mr. Lonsdale owed a duty of reasonable care to Ms. Clougherty in his actions and
9 conduct towards her. It was foreseeable and probable that Ms. Clougherty would suffer severe
10 emotional distress as a result of Mr. Lonsdale’s conduct described above.
11 113. Mr. Lonsdale was negligent by breaching the duty of care he owed Ms. Clougherty
12 when he repeatedly abused, manipulated, dominated, threatened, and harassed Ms. Clougherty,
13 doing so continuously and incessantly from February 2012 to February 2013.
14 114. Ms. Clougherty has suffered severe emotional distress as a direct and proximate
15 result of Mr. Lonsdale’s negligent actions towards her.
16 115. Mr. Lonsdale’s actions were a substantial factor in causing Ms. Clougherty’s
17 severe emotional distress.
18 116. As a direct and proximate result of Mr. Lonsdale’s tortious, wrongful, and
19 unlawful acts and conduct towards her, Ms. Clougherty has suffered past and future special
20 damages and past and future general damages in an amount to be proven at trial, but not less than
21 $75,000. Ms. Clougherty has been damaged and injured physically, emotionally, and financially,
22 including but not limited to suffering from pain, anxiety, depression, severe emotional distress,
23 embarrassment, ridicule, and PTSD, as well as loss of health, future relationships, income,
24 employment, and future career benefits and earning potential.
25 117. In engaging in the conduct herein alleged, Mr. Lonsdale acted with malice, fraud,
26 and oppression and in conscious disregard of Ms. Clougherty’s health, rights, dignity and well-
27 being, and intended to subject Ms. Clougherty to unjust hardship and mental anguish, thereby
28 warranting an assessment of punitive damages in an amount sufficient to punish Mr. Lonsdale
- 23 - COMPLAINT
2 COUNT VIII – NEGLIGENT RETENTION AND SUPERVISION

AGAINST FORMATION 8
3
118. Ms. Clougherty incorporates by reference all prior allegations in this Complaint as
4
if fully restated herein.
5
119. Formation 8 has a duty to retain agents who are fit and competent, to supervise its
6
agents, and to implement measures to protect third persons from the predictable and foreseeable
7
risks posed by its agents.
8
120. Formation 8 knew, or should have known through the exercise of reasonable
9
diligence, that Mr. Lonsdale, as an agent of Formation 8, was incompetent and unfit to perform
10
the duties for which he was responsible, and that undue risks to persons such as Ms. Clougherty
11
could or would result by way of Mr. Lonsdale’s abuse of the privileges and authority he was
12
granted.
13
121. Formation 8 knew, or should have known through the exercise of reasonable
14
diligence, that Mr. Lonsdale had initiated an inappropriate sexual relationship with his mentee—
15
Ms. Clougherty—who he then hired as an intern, that he continued to maintain said inappropriate
16
sexual relationship with Ms. Clougherty during the period of her internship, and therefore should
17
not have authorized Mr. Lonsdale’s supervision of Ms. Clougherty as an intern of Formation 8.
18
122. Formation 8 was negligent by breaching the duty of care owed to third persons
19
such as Ms. Clougherty by retaining and failing to supervise Mr. Lonsdale—its agent—in his
20
wrongful and tortious interactions with Ms. Clougherty.
21
123. Mr. Lonsdale’s actions towards Ms. Clougherty were foreseeable and easily
22
discoverable and were committed during and facilitated by an internship that furthered the
23
interests of Formation 8.
24
124. Formation 8 breached its duty of care by failing to implement measures to protect
25
third persons from foreseeable risks, unreasonable risks of harm, and the tortious, wrongful, and
26
harmful actions of its agent that were reasonably foreseeable and easily discoverable.
27
28
- 24 - COMPLAINT
2
125. Formation 8 failed to terminate Mr. Lonsdale or take any disciplinary action
3
against him. Instead, it retained him as its agent and enabled him to continue abusing and
4
assaulting Ms. Clougherty, one of its interns.
5
126. Formation 8’s failure to train, supervise, and terminate Mr. Lonsdale was the direct
6
and proximate cause of many of Ms. Clougherty’s injuries. Ms. Clougherty has suffered past and
7
future special damages and past and future general damages in an amount to be proven at trial,
8
but not less than $75,000. Ms. Clougherty has been damaged and injured physically, emotionally,
9
and financially, including but not limited to suffering from pain, anxiety, depression, severe
10
emotional distress, embarrassment, ridicule, and PTSD, as well as loss of health, future
11
relationships, income, employment, and future career benefits and earning potential.
12
PRAYER FOR RELIEF
13
WHEREFORE, having stated her Complaint, Plaintiff respectfully prays for judgment
14
against Defendants as follows:
15
A. For general and special damages in an amount to be determined at trial, but not
16
less than $75,000;
17
B. For pre- and post-judgment interest according to proof;
18
C. For punitive and exemplary damages;
19
D. For costs of suit including reasonable attorneys’ fees, costs, and expenses; and
20
E. For all other relief this Court may deem just, equitable, and proper.
21
22 Dated: January 27, 2015 Respectfully submitted,
23 THE LIU LAW FIRM, P.C.
24 By: /s/ Jennifer L. Liu

Jennifer L. Liu
25
Jennifer L. Liu, Cal. Bar No. 279370
26 THE LIU LAW FIRM, P.C.
324 Day Street
27 San Francisco, CA 94131
Telephone: (415) 896-4260
28 Fax: (415) 231-0011
- 25 - COMPLAINT

4 Boulder, CO 80302
Telephone: (303) 442-6514
5 Fax: (303) 442-6593
6
L. LIN WOOD, P.C.
Atlanta, GA 30309
10 Telephone: (404) 891-1402
Fax: (404) 506-9111
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 26 - COMPLAINT
2 DEMAND FOR JURY TRIAL
3 Plaintiff hereby demands a jury trial on all causes of action and claims with respect to
4 which she has a right to a jury trial.
5
Dated: January 27, 2015 Respectfully submitted,
6
7
By: /s/ Jennifer L. Liu
8 Jennifer L. Liu
9 Jennifer L. Liu, Cal. Bar No. 279370)

10 324 Day Street
San Francisco, CA 94131
11 Telephone: (415) 896-4260
Fax: (415) 231-0011

15 Boulder, CO 80302
Telephone: (303) 442-6514
16 Fax: (303) 442-6593
17
L. LIN WOOD, P.C.
Atlanta, GA 30309
21 Telephone: (404) 891-1402
Fax: (404) 506-9111
24
25
26
27
28
- 27 - COMPLAINT

Formation 8 Joe Lonsdale Lawsuit

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Case3:15-cv-00382 Document1 Filed01/27/15 Page1 of 28

1 John C. Clune, Colorado Bar No. 27684

11 Jennifer L. Liu, Cal. Bar No. 279370

15 Attorneys for Plaintiff Elise Clougherty

14 if fully restated herein.

16 another when that person:

18 Cal. Civ. Code § 1708.6

20 if fully restated herein.

22 domestic violence if the plaintiff proves the following elements:

24 subdivision (a) of Section 13700 of the Penal Code.

26 plaintiff as defined in subdivision (b) of Section 13700 of the Penal Code.”

February 2012 and ended in February of 2013.

23 Cal. Civ. Code § 52.4

25 if fully restated herein.

27 discrimination” and includes:

2 COUNT V – SEXUAL HARASSMENT

and deter others from engaging in similar conduct.

2 COUNT VIII – NEGLIGENT RETENTION AND SUPERVISION

22 Dated: January 27, 2015 Respectfully submitted,

23 THE LIU LAW FIRM, P.C.

24 By: /s/ Jennifer L. Liu

2 John C. Clune, Colorado Bar No. 27684

12 Attorneys for Plaintiff Elise Clougherty

2 DEMAND FOR JURY TRIAL

4 which she has a right to a jury trial.

9 Jennifer L. Liu, Cal. Bar No. 279370)

13 John C. Clune, Colorado Bar No. 27684

23 Attorneys for Plaintiff Elise Clougherty

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