1 Ashley Parris, Esq. (SBN 239537) MCELROY PARRIS TRIAL LAWYERS 2 407 Bryant Circle, Suite F Ojai, CA 93023 3 Tel: (805) 272-4001 Fax: (805) 719-6858 4 Email:
[email protected] 5 Carrie Goldberg, Esq. (NYS Bar No. 4542411) 6 C.A. GOLDBERG PLLC 16 Court Street 33rd Floor 7 Brooklyn, NY 11241 Tel: 646-666-8908 8 Email:
[email protected] (Pro Hac Vice Application To Be Filed) 9 10 Attorneys for Plaintiff, KATHERINE HILL 11 12 SUPERIOR COURT OF THE STATE OF CLAIFORNIA 13 FOR THE COUNTY OF LOS ANGELES 14 KATHERINE HILL, CASE NO.: 15 Plaintiff, 16 1. ACTION BASED ON CIVIL CODE v. SECTION 1708.85 17 KENNETH HESLEP, JENNIFER VAN 2. CIVIL CONSPIRACY TO VIOLATE 18 LAAR, JOSEPH MESSINA, MAIL CIVIL CODE SECTION 1708.85 MEDIA, INC., SALEM MEDIA GROUP, 19 INC., and DOES 1-50, inclusive, 3. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 20 Defendants. 4. ACTION BASED ON BUS. PROF. CODE 21 SECTION 17200 22 DEMAND FOR JURY TRIAL 23 24 25 Plaintiff KATHERINE HILL initiates this suit, by her attorneys, McElroy|Parris Trial 26 Lawyers by Ashley Parris, Esq. and C.A. Goldberg PLLC, by Carrie Goldberg, Esq. against 27 Defendants KENNETH HESLEP, JENNIFER VAN LAAR, JOSEPH MESSINA, MAIL MEDIA, 28 INC., SALEM MEDIA GROUP, INC., and DOES 1 through 50 as follows: 1 COMPLAINT FOR DAMAGES 1 PRELIMINARY STATEMENT 2 1. This case is about a man, Defendant Kenneth Heslep, stopping at nothing to destroy 3 the life of his ex-wife, Plaintiff Katherine Hill (“Hill”), a US Congress newcomer, when she dared 4 end their relationship after more than fifteen years of physical, sexual, verbal, emotional and 5 psychological abuse that began when she was only sixteen and he was twenty.