This is an action brought by Plaintiff seeking damages from Defendants for sexual assault,

sexual battery, and/or violations of the Trafficking Victims Protection Reauthorization Act, and

any other cause(s) of action that can be inferred from the facts set forth herein. 27

when you say settled, is that fake too

Upon information and belief, Defendants Interscope and Nothing Records were

aware of Defendant Warner’s practice of sexually assaulting minors, and aided and abetted such behavior. As a result of Brian Warner’s sexual abuse and assault, enabled and encouraged by Defendants Interscope and Nothing Records, Plaintiff has suffered severe emotional, physical and psychological distress, including shame, and guilt, economic loss, economic capacity and emotional loss.

6. Defendants Interscope and Nothing Records knowingly, intentionally, willfully, deliberately, and recklessly fostered a pervasive and hostile environment for the purpose of financial gain that utterly disregarded the rights and safety of the band’s young fans. As a result, Plaintiff has suffered humiliation, shame, and horror that she will continue to suffer for the rest of her life.


7. Plaintiff Jane Doe, is an adult female residing in Maryland. The name utilized by Plaintiff in this Complaint is fictitious to protect her privacy as a victim of child and adult sexual assault and molestation.