Professional Documents
Culture Documents
Bassnectar Lawsuit
Bassnectar Lawsuit
RACHEL RAMSBOTTOM, :
ALEXIS BOWLING :
Plaintiffs, :
: CIVIL ACTION NO.
:
v. :
: JURY TRIAL DEMANDED
LORIN ASHTON, :
AMORPHOUS MUSIC, INC., :
BASSNECTAR TOURING, INC., :
REDLIGHT MANAGEMENT, INC., :
C3 PRESENTS, L.L.C, :
INTERACTIVE GIVING FUND, :
Defendants. :
Plaintiffs Rachel Ramsbottom and Alexis Bowling, by and through undersigned counsel,
hereby states as follows in support of their Complaint against Defendants Lorin Ashton a/k/a
(“Bassnectar Touring”), Redlight Management, Inc. (“Redlight”), C3 Presents, L.L.C (“C3”) and
INTRODUCTION
1. With the rapid rise of technological advances in the twenty-first century, a new
genre of music was born. Electronic Dance Music, popularly known as EDM, captured a
generation. As this new genre rose in popularity, so did the industry around it. Festivals and
2. Lorin Ashton, popularly known by his stage name “Bassnectar,” was regarded as
one of the leading artists of the EDM scene, traveling from coast to coast performing shows and
showcased in large clubs like the 9:30 Club in Washington, D.C. and New York's Terminal 5.1
3. Bassnectar’s popularity became so great, in fact, that he began to host his own
festivals including “Bass Center” and “Bass Island.” Out of nine headlining shows reported to
Billboard Boxscore in 2011, Bassnectar sold out eight of them and grossed $1.1 million dollars.2
4. Bassnectar’s following was a cultural movement in itself. His fans, dubbed “Bass
Heads” (not unlike the Grateful Dead’s “Deadheads”) would travel around the country making just
enough money to get to the next show, some attending upwards of thirty-five (35) shows in a year.
“In a lot of ways, Bassnectar is a cult of personality. Ashton serves as a kind of tribal leader
for his fans, a big brother with bass. He sees the project as a cultural and social concern,
not merely a musical one, and speaks of his hardcore fans, known as Bass Heads, like a
family . . . Bass Heads in turn show loyalty for Ashton and a communitarian spirit. It's a
subculture of thousands across the country who are ready to show up anywhere he plays .
. .”3
5. Unlike many artists, whose success relies on their record sales, Bassnectar’s clout
was in his live performances. According to Bassnectar “[b]ecause our touring numbers were so
monstrous last year, I just realized I could put out a CD and every noteworthy publication in the
world could ignore it. But we’re still going to have 3,000 kids show up on a Monday night in
utilized his platform to encourage adolescents and young people to become activists. He developed
a charity for this purpose called the Interactive Giving Fund, formerly known as “BeInteractive.”
1
Jason Lipshutz, Let the Bass Build World Radio History (2012), https://worldradiohistory.com/hd2/IDX-
Business/Music/Billboard-Index/IDX/2012/2012-04-28-Billboard-Page-0036.pdf (last visited Feb 8, 2021).
2 Id.
3 Ian S. Port, Bass Instincts: How Bassnectar Came to Rule American Dance Music (2012),
https://archives.sfweekly.com/sanfrancisco/bass-instincts-how-bassnectar-came-to-rule-american-dance-
music/Content?oid=2187208&storyPage=2 (last visited Feb 5, 2021).
4 Id.
Conscious Alliance to organize fans to help work with local food shelters. On multiple occasions,
group of young people tasked with generating ideas and connecting with the “Bass Head”
community. AmBASSadors were also found at shows where they would search for others “like
them,” even selecting fans for opportunities to get backstage and meet Bassnectar.
organization originated by one man who provided a sense of belonging and righteousness to youth
that may have felt like they never got that in their lives before. He gave them friends, fun and a
purpose.5 In many ways he was held out by himself and others to his followers—both adults and
children—as God-like.
9. Yet, Bassnectar’s purported noble actions and reputation of being in service to some
greater good were nothing more than a veil to mask to his sinister desires and actions and a means
to use his power and influence to groom and ultimately sexually victimize underage girls.
10. Bassnectar solicited underage girls through various means, including, but not
limited to, Twitter, the BeInteractive amBASSadors, and live shows, presenting himself as an
advisor and peer in order to gain young girls trust, despite the fact that he was in his mid-thirties
at the time. Bassnectar was able to conceal yet maintain consistent contact with these underage
girls through secretive messaging apps which he required all communication to be funneled
through so that he could groom them for eventual commercial sex acts, get them to send him
sexually explicit photographs and further exploit them for his own gratification.
5Alycia Grace, Evidence Against Bassnectar [Interview] This is Perfect Harmony, LLC (2020),
https://thisisperfectharmony.com/2020/11/16/evidence-against-bassnectar-interview/ (last visited Feb 8, 2021).
tickets to his shows, exposing them to his thousands of young followers, “Bass Heads,” and a
12. Bassnectar would also dictate how these underage girls were to behave, who the
underage girls could hang out with and mandate that their contact with him be hidden from their
13. After performances, Bassnectar would invite these underage girls to his hotel room
and demand that the girls shower so that they were “clean.” He would then have sex with them,
requiring the sex to be unprotected, without a condom, and would provide large sums of cash and
14. Bassnectar would also require these underage girls to take sexually explicit
photographs of themselves with their cell phones and send them to him in violation of child
15. This action for damages is brought by Plaintiffs who are minor victims of sex
trafficking, child pornography, and other tortious acts and omissions who were groomed and
16. It was abundantly clear that Bassnectar was targeting and engaging in commercial
sex acts with minors and utilizing his shows and organizations to accomplish the exploitation of
young girls for his own sexual gratification. In fact, it was a running joke among those associated
with Bassnectar that he would have to find a date at a high school dance.
17. As such, remaining Defendants are companies that participated in a venture and
benefitted economically from Bassnectar and his companies while he was trafficking the Plaintiffs
and other underage girls. As a result of Bassnectar’s trafficking of minor girls and solicitation and
known Bassnectar was trafficking minor girls for commercial sex and other illegal activity.
participated in or benefited from facilitating a venture that they knew, or should have known, to
PARTIES
19. Plaintiff, Rachel Ramsbottom, is an adult female and a citizen of the state of
Tennessee.
20. Plaintiff, Alexis Bowling, is an adult female and a citizen of the state of Kentucky.
21. Plaintiffs’ claims are properly joined pursuant to Fed. R. Civ. Pro. 20 as they arise
out of the same transaction, occurrence, or series of transactions or occurrences and involve
common questions of law and/or fact, namely, the systematic grooming, trafficking and
solicitation/possession of child pornography by Bassnectar and the knowledge of same by the other
Defendants.
and resident of California with a home address of 5850 Romany Road, Oakland, CA 94618
incorporated in the state of California, and headquartered at 235 Park Avenue South, 9th Floor
New York, New York 10003. Ashton is the founder, chairman, figurehead, chief executive, and
corporation, is incorporated in the state of Delaware, and maintains an office in New York at: 235
Park Avenue South, 9th Floor New York, New York 10003. Ashton is the founder, chairman,
figurehead, chief executive, and icon of Bassnectar Touring Inc. Bassnectar utilized Bassnectar
exploitation.
Bristol Parkway, Culver City, CA 90230. Bassnectar is the founder and former chairman,
figurehead, chief executive, and icon of the IGF. Bassnectar utilized IGF to target, recruit and
26. Defendant Red Light Management, L.L.C. (hereinafter “Red Light”), a corporation,
is incorporated in the state of Oregon and is headquartered at 10 E 40th St #22, New York, NY
10016. Red Light Management participated in a venture with Bassnectar in which it managed,
promoted, recruited and profited from its’ venture with Ashton. Red Light knew, or should have
known, Bassnectar was engaging in the trafficking of and unlawful conduct with minors.
the state of Texas and is headquarter at 1645 E 6TH St Ste 150 Austin , TX, 78702-3386. C3
Presents, at all relevant times, managed Bassnectar and produced large festivals where Bassnectar
performed, including Electric Daisy Carnival, Camp Bisco, and Lalapalooza. Bassnectar utilized
these festivals, concerts and events to target young girls, like Plaintiffs, for sexual exploitation. C3
Presents participated in managing, promoting, recruiting, and profiting from its venture with
Ashton. C3 knew, or should have known, Bassnectar was engaging in the trafficking of minors.
JURISDICTION
28. This Court has subject matter jurisdiction under 28 U.S.C. § 1332 in that Plaintiffs
and Defendants are citizens of different states and the amount in controversy is in excess of
$75,000.
provides the district courts of the United States jurisdiction over violations of 18 U.S.C. § 1591.
30. This Court is “an appropriate district court of the United States” in accordance with
18 U.S.C. §1595.
31. Venue is proper in this district pursuant to 28 U.S.C. § 1391 because a substantial
part of the events or omissions giving rise to the claims asserted in this action occurred in the
32. Like many of their peers in high school, Plaintiffs had an interest in electronic dance
34. Bassnectar maintained control of the @Bassnectar Twitter account and used it to
35. Through the Bassnectar twitter account, Bassnectar found Plaintiffs and contacted
them through direct messages, providing his personal number and email to maintain
communication.
Plaintiffs’ lives and provided advice, including encouraging them to watch “American Beauty,” a
movie about an older man having a relationship with a young girl. Bassnectar referenced American
Beauty at his shows too. He used the visual of the scene with the actress laying in rose petals and
had rose petals fall from the sky at one of his New Years Eve shows.
39. Nevertheless, Bassnectar supplied tickets and travel arrangements for Plaintiffs to
40. Plaintiffs were subsequently invited to his hotel room where Bassnectar had sex
41. In exchange for the sexual encounters, Bassnectar gave Plaintiffs cash—in amounts
ranging from three-hundred ($300) to one thousand six hundred ($1,600) dollars.
42. Bassnectar maintained tight control over Plaintiffs, requiring them to follow certain
rules including:
a. Keeping the relationship secret; this included avoiding being seen in public
together;
condom);
f. Plaintiffs were not allowed to have sex with anyone else, but Bassnectar
43. At the heart of this action is Bassnectar’s use of the Bassnectar Companies to
facilitate and enable the sex trafficking of underaged girls in the United States.
venture, and Bassnectar uses the Bassnectar Companies’ brand, resources, and promotional events
to recruit, lure, entice, and/or groom his victims and force or coerce them, or knowing that the
victim has not attained the age of eighteen years, into engaging in commercial sex acts.
45. In turn, the Bassnectar Companies knowingly benefit from their participation in
46. Bassnectar, using the Bassnectar Companies’ resources, engaged in a pattern and
practice of recruiting, luring, enticing, obtaining, and grooming underaged girls, and causing them
through force, fraud or coercion, or knowing that the victim had not yet attained the age of eighteen
years, to engage in commercial sex acts through, among other means, providing cash payments
and other commercially lucrative benefits such as transportation and concert/event tickets.
commercial sex acts through him, as he is the founder of the Bassnectar Companies and intimately
48. Further, the Bassnectar Companies knowingly aided and abetted, facilitated, and
participated in Bassnectar’s illegal sex trafficking venture by being integrally involved in the
recruitment of the underaged victims and the logistical steps necessary for Bassnectar to recruit,
49. Bassnectar intentionally used the Bassnectar Companies’ resources to recruit, lure,
and entice children to cause them to engage in commercial sex acts and other degrading acts, for
sex acts.
outlaws using means of interstate or foreign commerce to recruit, entice, obtain, or lure a person
and force or coerce that person, or knowing that the person had not attained the age of eighteen
years, to engage in commercial sex acts. The Bassnectar Companies are guilty of aiding and
abetting Bassnectar’s violations of the TVPA and TVPRA by knowingly facilitating and enabling
52. The Bassnectar Companies also directly violated the TVPA because they
disregard of the fact, that Bassnectar used means of force, threats of force, fraud, and coercion to
“@evidenceagainstbassnectar”6 where dozens of young and underage women detailed the ways in
54. Terrified of his illegal conduct being exposed, Bassnectar contacted Plaintiffs,
telling them they were special, and that he would always love them, going so far as to offer money
55. Plaintiff, Rachel Ramsbottom, became a fan of Bassnectar in high school and
56. In September 2012, after tweeting about a Bassnectar show cancellation, Rachel
57. Bassnectar informed Rachel that he would be playing a show in Nashville, in her
home state of Tennessee. The first Bassnectar show Rachel went to was his New Years Eve show
6 https://linktr.ee/evidenceagainstbassnectar
Rachel the next day regardless. Rachel did not meet with him because she was with her brother at
the time.
58. However, Bassnectar provided his phone number and email address and maintained
communication with Rachel every day or every other day from the end of September 2012 until
May 2013.
59. During this time, Bassnectar was aware that Rachel was a minor and in high school.
Bassnectar would read Rachel’s school assignments and even asked her to write one for him.
Bassnectar said the paper he wanted Rachel to write him would take about 4-5 hours.
60. Bassnectar manipulated Rachel and gained the trust of Rachel by presenting himself
as a friend and a mentor, discussing school and offering his advice. Yet, his communications had
sexual undertones, grooming Rachel for what would later become Bassnectar sexually abusing and
exploiting Rachel while she was still a child under the age of eighteen. Examples include, but are
b. Telling her that every guy wants to have sex with her;
c. Directing Rachel to break up with her high school boyfriend at the time,
d. Telling Rachel her last name “blows [him] away” and was “really sexy;”
61. In May 2013, Bassnectar was in Memphis performing at the Beale Street Music
Festival.
62. On or about May 3, 2013 Rachel met Bassnectar at the Marriott Hotel in Memphis.
to meet him in the elevator. When she did, Bassnectar did not say a word to Rachel.
64. Instead, Bassnectar took Rachel to his hotel room and had sex with her. Bassnectar
refused to wear a condom and never asked if Rachel was on birth control.
65. Bassnectar provided Rachel with one thousand ($1,000) dollars in mixed bills after
birthday in Nashville and invited Rachel to stay with him at the Lowe’s hotel.
67. Bassnectar kept Rachel in the hotel room for approximately four (4) days.
68. During this time, Bassnectar required Rachel to hide when room service arrived
69. In addition to the sexual abuse described herein, Bassnectar was very controlling
d. Pressuring Rachel to change her last name of no one would ever take her
seriously.
70. Further, Rachel was required to follow Bassnectar’s rule: she was not allowed to
have sex with anyone else, but he could have sex with whomever he wanted and unprotected sex
71. On numerous occasions, when Rachel was a minor, Bassnectar solicited Rachel to
take and send sexually explicit photographs of herself while naked. Rachel complied. As such,
occasions.
72. November, 2013 was the last time Bassnectar and Rachel saw each other in person.
73. After the “MeToo” movement began in 2016, Bassnectar reached out to Rachel,
checking in with her often and telling her “you know I love you.”
74. In 2019, shortly after Rachel had started therapy as a result of what Bassnectar did
to her, she decided to tell Bassnectar for the first time that she was suffering as a result of what he
did to her when she was a minor. Bassnectar attempted to justify his behavior, again using
manipulation tactics. Bassnectar offered to pay for Rachel’s therapy or fly out for a therapy session
with Rachel.
75. After being publicly exposed in June 2020, Bassnectar began incessantly reaching
out to Rachel; when she blocked his number he continued to attempt to initiate contact via the
messaging app “WhatsApp.” Bassnectar also emailed Rachel before his last attempt to contact her
on “Whatsapp.”
77. Bassnectar and Rachel spoke on June 3, 2020. During the phone conversation,
Rachel confronted Bassnectar about the fact that she was taken advantage of, trafficked and that
78. In response, Bassnectar admitted his abuse of Rachel was “so inappropriate” and
79. Bassnectar admitted that he engaged with multiple women who were “too young,”
and acknowledged in his own words that there was an imbalance of power dynamic due to his age,
the fan/celebrity dynamic, his male privilege, and his celebrity privilege.
weren’t complicit,” going so far as to apologize to Rachel for “exploiting you and taking advantage
81. Ironically, Bassnectar repeatedly stated that he wanted to “take accountability” and
“make an example of myself” yet blamed Rachel for his inability to do so: “I could be doing so
much more if it wasn’t for one person who could push a button and put me in fucking jail.”
82. Importantly, Bassnectar admitted his conduct was illegal and referenced his risk of
a. “If you think it’s worth me living forever in a Tennessee jail to be raped or
beat to death…”
c. “The one thing that gets in the way is if I have to go to a Tennessee jail for
life.”
d. “Do you understand me taking accountability over the phone with you right
now . . . is colored by the fact that me talking to you can result in a Tennessee jail that is
e. “There is only one person who has the potential to take me from being really
83. During the phone conversation, Bassnectar repeatedly offered Rachel money and
84. Rachel has suffered substantial physical and psychological injuries and emotional
86. Bassnectar contacted Alexis through a direct message wishing her happy birthday.
Throughout her senior year, Bassnectar, through the @Bassnectar twitter account, would reply to
her tweets.
87. Around April 2014, Bassnectar provided Alexis with his personal email and
contacted her via email offering her tickets to his Las Vegas show.
88. Alexis drove to Las Vegas, but was not permitted in the venue because she was
89. Alexis reached out to Bassnectar to see if there was anything he could do, but he
could not help her. Instead, Bassnectar directed her and arranged for her to meet him near his hotel.
90. Bassnectar met Alexis near his hotel where he took her into the bushes and hid for
91. Afterwards, Bassnectar paid Alexis $300 in cash and instructed her to download
92. On or around July 1, 2014, Bassnectar flew to Kentucky to visit Alexis She picked
him up from the airport and took him to the Lexington Griffin Gate Marriott where he stayed for
four days. During this visit, Ashton had sex with Alexis
93. Bassnectar paid Alexis $1600 after he had sex with her.
94. Approximately two weeks later, Bassnectar again visited Alexis again and stayed
95. On approximately August 1, 2014, Bassnectar again visited Alexis and stayed at a
hotel in Covington, Kentucky. He again stayed for three or four days. During each visit, Bassnectar
97. Each time Bassnectar coerced Alexis, a minor, to take nude sexually explicit photos
of herself and send them to him he engaged in the manufacture and possession of child
pornography.
98. Following the death of her Father, Bassnectar told Alexis that he could offer
guidance and advice to Alexis like a father and do all the things a father would do for her.
99. Bassnectar dictated and controlled every aspect of Alexis’s life, telling her what
she could or could not do, who she could hang out with, what she could wear, etc.
100. Bassnectar required that Alexis not tell anyone about Bassnectar’s contact with her,
physical or otherwise. Bassnectar also ensured and required that he was not be seen in public with
101. Bassnectar lied to Alexis telling her that the reason she couldn’t tell anyone about
their contact or be seen in public with her is because he had never dated a younger girl, he didn’t
102. Between 2014-2016, Bassnectar paid for and flew Alexis all over the country to see
him while he was on tour. On most of these visits Bassnectar would make Alexis stay in his hotel
room the entire time. Bassnectar would have sex with Alexis during these visits. This occurred in
103. In December 2015, Bassnectar had Alexis fly to California to visit him at his home
in Oakland. Upon arrival, Bassnectar directed Alexis to take an Uber to a mini-mart, near his
house. This store was located at the base of his neighborhood and Bassnectar picked her up there.
104. The majority of the visit was spent in Bassnectar’s home. Bassnectar had sex with
Alexis during this visit. Afterwards, Bassnectar gave Alexis tickets to his show in Virginia.
get her a job with the prestigious Deborah Berke design firm.
106. Alexis applied for the job and was scheduled for a telephone interview. Bassnectar
was present for the telephone interview as Alexis was at his house in California at the time.
107. During the telephone interview, Alexis was asked why she knew about the San
Francisco position given that she had a Kentucky address. At that point, Bassnectar took the phone
108. In October 2016, Bassnectar had Alexis fly out to see Bassnectar at his home for
109. On June 13, 2020 Bassnectar contacted Alexis and told her about allegations of a
music teacher of his in high school having sexual contact with a minor. However, in an attempt to
manipulate Alexis, Bassnectar told Alexis that what happened between them was nothing like that.
He told Alexis how special she was to him and that he would “always love her” in an attempt to
maintain Alexis’s loyalty and prevent her from speaking out against his unlawful conduct.
and silence Alexis from speaking out about what Bassnectar did to her as a minor.
111. Alexis has suffered substantial physical and psychological injuries and emotional
CAUSES OF ACTION
COUNT I:
CONDUCT IN VIOLATION OF THE TRAFFICKING VICTIM PROTECTION
REAUTHORIZATION ACT, 18 U.S.C. § 1591(a)
PLAINTIFFS v. DEFENDANT LORIN ASHTON A/KA BASSNECTAR
for the purposes of a commercial sex act and in which the commercial sex act is induced by force,
fraud, or coercion.”
114. Pursuant to 18 U.S.C. §1591(a), all who knowingly provide or obtain commercial
sex that was provided or obtained through force, fraud, and coercion are guilty of sex trafficking.
This includes, at a minimum, both the ‘traffickers’ who recruit, harbor, transport, and provide
individuals for forced commercial sex work and those who obtain, solicit, or patronize forced
115. Pursuant to 18 U.S.C. §1591(a), anyone under the age of 18 engaging in the act of
116. Bassnectar, with the help of the Defendants and their resources, used his fame and
popularity through the Bassnectar brand, to recruit, solicit, and coerce underage girls into
117. Rachel Ramsbottom is a victim of sex trafficking with the meaning of 18 U.S.C.
§1591(a) and is therefore entitled to bring a civil action under 18 U.S.C. §1595.
118. Alexis Bowling is a victim of sex trafficking with the meaning of 18 U.S.C.
§1591(a) and is therefore entitled to bring a civil action under 18 U.S.C. §1595.
119. The actions, omissions, and/or commissions alleged in this pleading were the but-
120. Plaintiffs have suffered substantial physical and psychological injuries as a result
COUNT II:
BENEFITING FROM A SEX TRAFFICKING VENTURE IN VIOLATION OF THE
TRAFFICKING VICTIMS PROTECTION REAUTHORIZATION ACT, 18 U.S.C. §§
1591 AND 1595
121. Plaintiffs reallege and incorporate by reference all prior and subsequent paragraphs
122. Under 18 U.S.C. §1591 liability arises for entities who: (1) knowingly benefitted
financially or by receiving anything of value (2) from participation in a venture (3) it knew or
123. Pursuant to 18 U.S.C. §1591(a), anyone under the age of 18 engaging in the act of
Specifically, Defendants had a statutory obligation not to participate in or benefit from a venture
that they knew, or should have known, was engaged in violations of 18 U.S.C. §1591(a). At all
relevant times, Defendants breached this duty by participating in, and facilitating, the harboring
and provision of Plaintiffs for the purpose of commercial sex induced by fraud and coercion by
125. Defendants knew, or were in reckless disregard of the fact, that it was Bassnectar’s
pattern and practice to use the channels and instrumentalities of interstate and foreign commerce,
as well as Defendants’ resources to entice or recruit young and underage female fans into
126. Defendants knowingly benefited from, and received value for, their participation in
the venture, in which Ashton, with the Defendants knowledge, or in reckless disregard of the fact,
that Bassnectar would utilize his fame and influence through the Bassnectar brand, to solicit and
coerce Plaintiffs, who were under the age of eighteen, to engage in commercial sex acts.
commissions by their participation in managing, promoting, recruiting, and profiting off the
128. Rachel Ramsbottom is a victim of sex trafficking with the meaning of 18 U.S.C.
§1591(a) and is therefore entitled to bring a civil action under 18 U.S.C. §1595.
129. Alexis Bowling is a victim of sex trafficking with the meaning of 18 U.S.C.
§1591(a) and is therefore entitled to bring a civil action under 18 U.S.C. §1595.
130. Defendants’ conduct was in, or affected, interstate and/or foreign commerce.
Defendants knowingly benefited from participation in what they knew or should have known was
131. Defendants knowingly benefited from, and/or received something of value for their
participation in the venture, in which Defendants knew, should have known, or were in reckless
disregard of the fact that the Plaintiffs were engaged in commercial sexual acts while under the
age of eighteen.
132. Defendants’ employees and agents had actual knowledge or should have known
that they were facilitating and participating in a scheme to profit from the commercial sex acts of
minor children.
133. Defendants’ acts, omissions, and commissions, taken separately and/or together,
outlined above, constitute a violation of 18 U.S.C. §1595. Specifically, Defendants had a statutory
obligation not to benefit in any way from a venture they knew, or should have known, to engage
in violations of 18 U.S.C. §1591(a). At all relevant times, Defendants breached this duty by
134. Defendants’ conduct has caused Plaintiffs serious harm including, without
135. Plaintiffs reallege and incorporate by reference all prior and subsequent paragraphs
137. Plaintiffs were minors and victims of these violations of Sections 1591, 2252, and
2252A and suffered personal injury as a result of such violations and are eligible to sue and recover
suffered serious harm, including physical, psychological, financial, and reputational harm.
Plaintiffs’ rights. They are entitled to compensatory and punitive damages, and the costs of
Alexis Bowling request that a jury be selected to hear this case and render a verdict for the
Plaintiffs, and against the Defendants, and that the jury selected award damages to the Plaintiffs in
an amount which will effectively prevent other similarly caused acts and adequately reflects the
enormity of the Defendants’ wrong and injuries to the Plaintiffs due to the Defendants’ faulty
a. All available compensatory damages for the described losses with respect
Further, Plaintiffs request that the Court enter judgment consistent with the jury’s verdict,
and prays for any other damages and equitable relief the Court or jury deems appropriate under
the circumstances.
Brian Kent*
M. Stewart Ryan*
Alexandria MacMaster*
LAFFEY, BUCCI & KENT, LLP
1100 Ludlow Street, Suite 300
Philadelphia, PA 19107
(T): (215) 399-9255
(E): [email protected]
[email protected]
[email protected]
Date: April 5, 2021 *pro hac vice application forthcoming