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1 David Matthew Haynie Texas Bar No. 24087692 2 Ashley Pileika 3 New York Bar No. 974605 FORESTER HAYNIE PLLC 4 400 North Saint Paul St., Suite 700 Dallas, TX 75201 5 P: 214-210-2100 | F: 214-346-5909 [email protected] 6 [email protected] 7 Damon J. Baldone 8 Louisiana Bar Roll No. 21997 DAMON J. BALDONE & ASSOCIATES 9 162 New Orleans Blvd. Houma, LA 70364 10 P: 985-868-3427 11 F: 985-872-2319 [email protected] 12 Attorneys for Plaintiff Jane Doe 13 IN THE UNITED STATES DISTRICT COURT 14 FOR THE DISTRICT OF ARIZONA 15 Jane Doe, an individual, Case No. 16 Plaintiff, 17 v. COMPLAINT AND JURY DEMAND 18
19 Gordon Sumner, a/k/a Sting, an individual; The Police; Frontier Booking International, 20 Incorporated a/k/a FBI; John Doe 1-100; Jane Doe 1-100; and Black & White Corporations 1- 21 100, 22 Defendants.
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24 COMES NOW Plaintiff, Jane Doe (“Plaintiff”), by and through her attorneys of record,
25 and shows unto the Court the following:
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COMPLAINT AND DEMAND FOR JURY TRIAL Case 2:20-cv-02217-SRB Document 1 Filed 11/18/20 Page 2 of 16
1 INTRODUCTION
2 1. Defendant The Police (“The Police”) are a rock band formed in 1977. The band has 3 primarily consisted of Defendant Gordon Sumner (“Sting”), Andy Summers, and Stewart 4 Copeland. 5 2. The Police’s 1978 debut album Outlandos d’Amour reached No. 6 in the UK and 6
7 that was quickly followed by their second album, Reggatta de Blanc in 1979, which reached No.
8 1 on the UK charts.
9 3. After their debut album was released, The Police started on multiple tours across 10 the United States in late 1978, and into 1979. 11 4. In 1979, Plaintiff and a friend attended an event at which they would have the 12 opportunity to meet members of The Police. Later that same day, Plaintiff and her family attended 13 The Police’s performance in Tempe, Arizona. 14
15 5. After the performance, Sting invited Plaintiff to an afterparty and ultimately took
16 her back to his hotel room. Sting was then a twenty-seven-year-old married adult, while Plaintiff
17 was only a fifteen-year-old child. 18 6. At the party in Phoenix and at the hotel in Tempe, Arizona, Sting sexually assaulted 19 and raped Plaintiff. This action is brought to redress the harm that Plaintiff experienced then and 20 continues to experience today due to Defendant Sting’s misconduct. 21
22 7. Plaintiff grew up in a loving and religious household in Arizona and was a fan of
23 The Police. Plaintiff saved up and purchased tickets to the band’s show for her parents as her father
24 really liked the song “Roxanne”. At the time of the rape, Plaintiff had never been with another
25 person sexually. 26
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1 8. This statutory rape caused and continues to cause Plaintiff immense harm. Though
2 Plaintiff has attended therapy and counseling for many years, she continues to feel the vast harmful 3 effects of Defendants’ behavior and suffers from flashbacks every time she hears a song by The 4 Police or Sting and every time she sees an image of him. She brings this action seeking, at last, 5 some remedy for Defendants’ egregious abuse inflicted upon her when she was a child. 6
7 9. In May 2019, the state of Arizona enacted H.B. 2466. The bill, which passed
8 unanimously in the Arizona State Legislature, strengthens protections for victims of child sexual
9 abuse by extending the amount of time victims have to pursue civil action against perpetrators. 10 H.B. 2466 allows victims who did not have the opportunity to take civil action for their abuse due 11 to the previous two-year limit to bring a claim against their perpetrator until December 31, 2020. 12 JURISDICTION 13 10. This Court has diversity jurisdiction over the claims in this Complaint because the 14
15 aggregate amount in controversy exceeds the sum of $75,000.00 and is between citizens of
16 different states. 28 U.S.C. § 1332(a)(1).
17 11. Venue is proper within this District under 28 U.S.C. § 1391 because the acts, events, 18 and/or omissions at issue took place in Maricopa County, Arizona, which is in this District and 19 this Division. 20 PARTIES 21
22 12. Plaintiff, Jane Doe, is a citizen and resident of Sonoma County, California. Plaintiff
23 was born in 1963 and is pursuing this action because she was raped by Sting in 1979, when she
24 was only 15 years old. Consequently, the statutory rape was the direct and proximate result of
25 Defendants’ conduct. 26
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1 13. Defendant Gordon Sumner a/k/a “Sting” is an individual and is domiciled and a
2 citizen of New York County, New York. Sting was a member of the band, The Police and had 3 recording deals with A&M Records, which ultimately became part of Interscope and Universal 4 Records, with which Sting still has record deals. 5 14. Defendant The Police is a general partnership for profit with its principal place of 6
7 business in New York County, New York and does business in the State of Arizona. Defendant
8 The Police consists of general partners Gordan Sumner a/k/a Sting, Stewart Copeland, and Andy
9 Summers. 10 15. Defendant Frontier Booking International, Incorporated (“Frontier”) is a Delaware 11 corporation with its headquarters and principal place of business in New York City, New York 12 and does business in the State of Arizona. Defendant Frontier Booking International, Incorporated 13 is one of the nation’s leading talent agencies, representing a variety of successful performers from 14
15 actors and models to singers, designers, and voice-over artists.
16 16. Frontier was founded by Ian Copeland, the older brother of The Police’s drummer,
17 Stewart Copeland. 18 17. At all times relevant to this Complaint, Frontier was the entity and agency that was 19 responsible for discovering, promoting, managing, and booking events for Sting and The Police 20 and booked and managed their tours, including those in 1978-1980. 21
22 18. Defendants Frontier and The Police, acting through their agents of any kind,
23 recording artists, and employees, caused acts, events, or omissions to occur in Maricopa County,
24 Arizona out of which these claims arise.
25 19. Defendants Frontier and The Police have several programs and events that seek out 26 the participation of children in their activities. These Defendants, through their officials, have 27
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1 control over those activities involving children. These Defendants have the power to appoint,
2 supervise, monitor, and fire each person working with children within their sponsored events and 3 activities. 4 20. Defendant Sting was and/or is under the supervision, employment and/or control of 5 Defendants Frontier and The Police when he committed the wrongful acts, events, and/or 6
7 omissions.
8 21. At all times alleged, Frontier, The Police, their employees, officials, and/or agents
9 were acting within the course and scope of employment or, alternatively, acting within their actual 10 or apparent authority. At all times alleged, Sting was acting as an agent or employee of Defendants 11 Frontier and The Police and was acting within the course and scopes of his employment and or 12 actual or apparent authority of those Defendants. The wrongful acts, events, or omission 13 committed by Defendants including Sting acted individually and in conspiracy with the other to 14
15 hide and cover up this sexual assault and rape.
16 22. Defendants JOHN DOE 1-100, JANE DOE 1-100, and BLACK & WHITE
17 CORPORATIONS 1-100, are fictious names designating an individual or individuals or legal 18 entities not yet identified who have acted in concert with the named Defendants either as principals, 19 agents, co-participants, or co-conspirators whose true names Plaintiff may insert when identified. 20 23. Plaintiff is informed and believes, and on that basis alleges that at all times alleged 21
22 herein, Defendants and each of them and JOHN DOES 1-100, JANE DOES 1-100, and BLACK
23 & WHITE CORPORATIONS 1-100, inclusive were the agents, representatives, and/or employees
24 of each and every other Defendant. In doing the things hereinafter alleged, Defendants and each
25 of them, JOHN DOES 1-100, JANE DOES 1-100, and BLACK & WHITE CORPORATIONS, 26 inclusive were acting within the course and scope of said alternative personality, capacity, 27
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1 indemnity, agency, representation, and or employment and were within their actual or apparent
2 authority. 3 STATEMENT OF FACTS 4 24. Upon information and belief, that at all times herein mentioned, Defendant, Gordon 5 Sumner, has also been known as “Sting.” 6
7 25. Upon information and belief, that at all times herein mentioned, Sting was a
8 performer and member of the band The Police.
9 26. That at all times herein mentioned, Plaintiff was under the age of 18 years old. 10 27. On May 14, 1979, a record store then located in Papago Plaza in Scottsdale, 11 Arizona, World Records, held an event in which fans were encouraged and able to meet members 12 of the band, The Police. 13 28. Defendant Sting met Plaintiff during the event held at World Records. Sting 14
15 interacted with Plaintiff and took several photographs with Plaintiff while at the event held at
16 World Records. While there, Sting began grooming Plaintiff and asked her how old she was and
17 if she was coming to his show later that evening. Plaintiff informed Sting that she was 15 years 18 old and that she would in fact be at the show later that night. 19 29. The Police’s drummer, Stewart Copeland, filmed throughout the event. Eventually, 20 Stewart Copeland made a film that featured some of this footage, titled Everyone Stares: The 21
22 Police Inside Out, in which the Plaintiff is included.
23 30. After the event held at World Records, Plaintiff returned home to get ready for the
24 concert that night. Later that same day, May 14, 1979, The Police performed at Dooley’s, a club
25 in Tempe, Arizona. Plaintiff, her friend, and her parents visited Dooley’s to watch The Police 26 perform. Plaintiff went to the show with her friend, and her parents went to the show separately. 27
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1 31. While at the concert at Dooley’s, Plaintiff ventured away from her friend. Before
2 The Police began performing, Sting and the other members of The Police walked through the 3 audience at Dooley’s and visited with members of the audience. Sting found Plaintiff in Dooley’s 4 and talked to her briefly and asked her to sit on his lap during the opening band’s performance. 5 Sting placed Plaintiff on his lap and talked to her about the band. 6
7 32. Sting and The Police then performed their set at Dooley’s. After The Police
8 performed, Sting informed Plaintiff of a house party being held that night in Phoenix. Sting asked
9 Plaintiff to attend the house party with him and others, and Plaintiff agreed. 10 33. Sting and Plaintiff entered a vehicle driven by The Police’s guitarist, Andy 11 Summers, along with two unidentified women. Plaintiff sat in the front passenger’s seat of the 12 vehicle and spoke primarily with Andy Summers from the venue to the house in Phoenix. 13 34. Sting sat in the center backseat of the vehicle with the two other unidentified 14
15 women on either side of him. During the ride from Dooley’s to the house in Phoenix, Sting
16 repeatedly touched Plaintiff’s shoulder in attempts to gain her attention.
17 35. Once they arrived to the house in Phoenix, all persons in the car went inside the 18 house. Sting then led the Plaintiff to the backyard, and the pair sat together on a chaise lounge 19 chair. During the encounter in the backyard, Sting kissed Plaintiff, touched her breasts, and 20 touched her genitals. Plaintiff then informed Sting again that she was only 15 years old. Sting then 21
22 asked her if she was a virgin, to which she replied that she was a virgin and had never been with
23 anyone before. Nevertheless, Sting persisted talking and touching Plaintiff until they left the party.
24 36. Sting, Plaintiff, and Andy Summers left the party together in the same car. Plaintiff
25 believed that she would reunite with her friend and return home upon arrival at the venue. 26
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1 However, the car went to the Vagabond Inn, the hotel where members of The Police were staying
2 while in Tempe, Arizona, which was across the street from the venue. 3 37. Once they arrived and Plaintiff realized her friend was not at the venue, Sting and 4 Plaintiff walked to Sting’s hotel room. While in the room, Stewart Copeland filmed Sting and 5 Plaintiff speaking to each other. Stewart Copeland exited the room at the urging of Sting, leaving 6
7 Sting and Plaintiff, a fifteen year old girl, alone in Sting’s hotel room.
8 38. Sting removed his pants, exposing himself, and asked Plaintiff if she “wanted a
9 lolly.” Sting then turned Plaintiff around and lifted her dress. During the encounter in the hotel 10 room, Sting had Plaintiff perform oral sex on him and Sting vaginally penetrated Plaintiff with his 11 penis. 12 39. After the rape in the hotel room, Sting led Plaintiff out of the hotel room and sent 13 her home in a taxi. Upon returning home, Plaintiff went to take a shower and discovered she was 14
15 bleeding in her vaginal region and was in significant amount of pain. Plaintiff never saw Sting
16 again after that, nor heard from him.
17 40. Shortly after the incident, Sting famously wrote the lyrics for Don’t Stand So Close 18 to Me. The Lyrics of the song state: 19 Young teacher, the subject 20 Of schoolgirl fantasy She wants him so badly 21 Knows what she wants to be 22 Inside her there's longing This girl’s an open page 23 Book marking - she's so close now This girl is half his age… 24 Her friends are so jealous 25 You know how bad girls get 26 Sometimes it's not so easy To be the teacher's pet 27 Temptation, frustration
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1 So bad it makes him cry Wet bus stop, she's waiting 2 His car is warm and dry 3 41. The song is about mixed feelings of lust, fear and guilt that a female student has for 4 a schoolteacher and vice versa, and inappropriateness leading to confrontation which is unraveled 5 later on in the song. The line, “Just like the old man in that book by Nabokov,” alludes to Vladimir 6
7 Nabokov’s infamous novel, Lolita, which narrates a pedophile’s yearlong sexual exploitation of a
8 young girl. Sting later said of the song’s inspiration, “You have to remember we were blond
9 bombshells at the time and most of our fans were young girls, so I started role playing a bit. Let's 10 exploit that.” 11 42. Within a year, Plaintiff told her closest friends about the incident. Plaintiff told 12 several family members about the incident. Jane Doe has visited therapists throughout her life and 13 has spoken to several therapists about the incident. In her adult life, Plaintiff has been unable to 14
15 maintain a healthy relationship as a result of this traumatic incident.
16 43. As stated above, Plaintiff did not and was not able to give free or voluntary consent
17 to the sexual acts perpetrated against her by Sting, as Plaintiff was a minor child at the time and 18 was only fifteen years old. 19 COUNT I 20 SEXUAL ASSUALT/SEXUAL ABUSE/SEXUAL CONDUCT WITH A MINOR
21 44. Plaintiff incorporates all other paragraphs as if fully set forth herein. 22 45. Defendant Sting intentionally, knowingly, recklessly, or negligently engaged in 23 sexual contact with Plaintiff. 24 46. Defendant Sting intentionally, knowingly, recklessly, or negligently engaged in 25
26 sexual contact without Plaintiff’s consent and when she was a minor incapable of consenting to
27 such sexual contact.
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1 47. As a direct and proximate cause of Defendant Sting’s wrongful acts, Plaintiff
2 suffered and will continue to suffer in the future physical and emotional injury including, but not 3 limited to, great pain of mind and body, shock, mental anguish, emotional distress, embarrassment, 4 loss of self-esteem, disgrace, humiliation, anger, rage, frustration, loss of enjoyment of life, loss 5 of consortium, loss of love and affection, sexual dysfunction, past and future medical expenses for 6
7 psychological treatment, therapy, and counseling, and past and future loss of earnings.
8 48. The allegations set forth in this Count constitute traditional negligence and
9 negligence per se for laws enacted for the protection of a specific class of persons of which Plaintiff 10 is a member. 11 49. WHEREFORE, Plaintiff demands judgment against the Defendant, and requests 12 compensatory and punitive damages, together with interest, costs of suit, attorneys’ fees, and such 13 further relief as the Court deems equitable and just. 14
15 COUNT II NEGLIGENCE 16 50. Plaintiff incorporates all other paragraphs as if fully set forth herein. 17 51. Defendants The Police and Frontier owed Plaintiff a duty of reasonable care to 18
19 protect the Plaintiff from injury.
20 52. Defendants The Police and Frontier owed Plaintiff a duty of reasonable care
21 because they solicited youth and parents for participation in their programs, events, and concerts. 22 They promoted their events and programs as being safe for children and encouraged their agents, 23 including Sting, to spend time and interact with underage fans. 24 53. Because of this, Defendants The Police and Frontier owed Plaintiff a duty to 25
26 properly supervise her and to prevent harm from foreseeable dangers.
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1 54. By establishing tours, meet and greets, and events marketed at children, Defendants
2 The Police and Frontier owed Plaintiff a duty to properly supervise her to prevent harm from 3 foreseeable dangers. 4 55. Defendants The Police and Frontier breached their duties to Plaintiff. These 5 Defendants failed to use ordinary care in determining whether their events were safe and/or in 6
7 determining whether they had sufficient information to represent their events as safe. Defendants
8 The Police and Frontier breached their duties including, but not limited to: failure to protect
9 Plaintiff from a known danger, failure to properly implement policies and procedures to prevent 10 child sex abuse, failure to properly implement policies and procedures to prevent child sex abuse, 11 failure to take reasonable measures to ensure that policies and procedures to prevent child sex 12 abuse were working, failure to adequately inform families and children of the risks of child sex 13 abuse, failure to investigate risks of child sex abuse, failure to properly train the employees and 14
15 agents, failure to protect the children at their events and programs from child sex abuse, failure to
16 adhere to the applicable standard of care for child safety, failure to investigate the amount and type
17 of information necessary to represent the events, concerts, programs, agents, employees, and 18 bandmembers as safe, and failure to properly train their employees and/or agents to identify signs 19 of child sex abuse. 20 56. Defendants The Police and Frontier breached their duties to Plaintiff by failing to 21
22 use reasonable care. These Defendants’ failures include, but are not limited to, failing to properly
23 supervise Defendant Sting and the other members of The Police, failing to properly supervise
24 Plaintiff, and failing to protect Plaintiff from a known or foreseeable danger.
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1 57. Defendants The Police and Frontier knew or should have known that Sting was a
2 danger to children before Sting raped Plaintiff. Prior to the sexual abuse of Plaintiff, Defendants 3 The Police and Frontier learned or should have learned that Sting was not fit to work with children. 4 58. Defendants knew or should have known that there was a risk of child sex abuse for 5 children participating in events, programs, and activities within the control of The Police and 6
7 Frontier. At the very least, The Police and Frontier knew or should have known that they did not
8 have sufficient information about whether or not there was a risk of child sex abuse for children
9 participating in their events, programs, and activities. 10 59. Defendants’ actions created a foreseeable risk of harm to Plaintiff. As a vulnerable 11 child participating in the programs and activities Defendants marketed and offered to minors, 12 Plaintiff was a foreseeable victim. Additionally, as a vulnerable fifteen-year-old child to whom 13 Sting had access through Defendants’ events, programs, and activities, Plaintiff was a foreseeable 14
15 victim.
16 60. As a direct and proximate cause of Defendants’ wrongful acts, Plaintiff suffered
17 and will continue to suffer the future physical and emotional injury including, but not limited to, 18 great pain of mind and body, shock, mental anguish, emotional distress, embarrassment, loss of 19 self-esteem, disgrace, humiliation, anger, rage, frustration, loss of enjoyment of life, loss of 20 consortium, loss of love and affection, sexual dysfunction, past and future medical expenses for 21
22 psychological treatment, therapy, and counseling, and past and future loss of earnings.
23 61. WHEREFORE, Plaintiff demands judgment against Defendants Police and
24 Frontier and requests compensatory and punitive damages, together with interest, costs of suit,
25 attorneys’ fees, and such further relief as the Court deems equitable and just. 26
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1 COUNT III INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 2 3 62. Plaintiff incorporates all other paragraphs as if fully set forth herein.
4 63. Sting’s wrongful conduct, including rape, exceeded the bounds of decency and was
5 extreme and outrageous, causing Plaintiff to suffer severe emotional and psychological distress.
6 64. In committing these acts described above, Sting acted intentionally and/or 7 recklessly. 8 65. As a direct and proximate cause of Defendant’s wrongful conduct, Plaintiff suffered 9 and will continue to suffer the future physical and emotional injury including, but not limited to, 10
11 great pain of mind and body, shock, mental anguish, emotional distress, embarrassment, loss of
12 self-esteem, disgrace, humiliation, anger, rage, frustration, loss of enjoyment of life, loss of
13 consortium, loss of love and affection, sexual dysfunction, past and future medical expenses for 14 psychological treatment, therapy, and counseling, and past and future loss of earnings. 15 66. WHEREFORE, Plaintiff demands judgment against the Defendant, and requests 16 compensatory and punitive damages, together with interest, costs of suit, attorneys’ fees, and such 17 further relief as the Court deems equitable and just. 18
19 COUNT IV ASSAULT 20 67. Plaintiff incorporates all other paragraphs as if fully set forth herein. 21
22 68. Defendant Sting intentionally, knowingly, and/or recklessly caused serious
23 physical and mental/emotional injury to Plaintiff.
24 69. Sting intentionally, knowingly, recklessly, and/or negligently placed Plaintiff in
25 reasonable apprehension of imminent physical injury. 26
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1 70. Sting intentionally, knowingly, recklessly and/or negligently touched Plaintiff with
2 the intent to injure, insult, or provoke. 3 71. As a direct and proximate cause of Sting’s abuse of Plaintiff, Plaintiff suffered and 4 will continue to suffer the future physical and emotional injury including, but not limited to, great 5 pain of mind and body, shock, mental anguish, emotional distress, embarrassment, loss of self- 6
7 esteem, disgrace, humiliation, anger, rage, frustration, loss of enjoyment of life, loss of consortium,
8 loss of love and affection, sexual dysfunction, past and future medical expenses for psychological
9 treatment, therapy, and counseling, and past and future loss of earnings. 10 72. WHEREFORE, Plaintiff demands judgment against the Defendant, and requests 11 compensatory and punitive damages, together with interest, costs of suit, attorneys’ fees, and such 12 further relief as the Court deems equitable and just. 13 COUNT V 14 BATTERY 15 73. Plaintiff incorporates all other paragraphs as if fully set forth herein. 16 74. Defendant Sting intentionally, knowingly, and/or recklessly caused serious 17 physical and mental/emotional injury to Plaintiff. 18
19 75. In committing the acts described above, Sting intentionally engaged in unlawful
20 and intentional touching or application of force to Plaintiff’s person.
21 76. Sting intentionally touched Plaintiff in a rude, insolent, or angry manner. 22 77. An offensive contact to Plaintiff’s person occurred as a result of Sting’s conduct. 23 78. As a result of Sting’s actions, Plaintiff suffered damages in an amount to be 24 determined at trial. 25
26 79. As a direct and proximate cause of Sting’s abuse of Plaintiff, Plaintiff suffered and
27 will continue to suffer the future physical and emotional injury including, but not limited to, great
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1 pain of mind and body, shock, mental anguish, emotional distress, embarrassment, loss of self-
2 esteem, disgrace, humiliation, anger, rage, frustration, loss of enjoyment of life, loss of consortium, 3 loss of love and affection, sexual dysfunction, past and future medical expenses for psychological 4 treatment, therapy, and counseling, and past and future loss of earnings. 5 80. WHEREFORE, Plaintiff demands judgment against the Defendant, and requests 6
7 compensatory and punitive damages, together with interest, costs of suit, attorneys’ fees, and such
8 further relief as the Court deems equitable and just.
9 JURY TRIAL DEMAND 10 81. Plaintiff demands a trial by jury on all of the triable issues within this pleading. 11 PRAYER FOR RELIEF 12 82. WHEREFORE, Plaintiff prays for the following relief against Defendants: 13 a) For Plaintiff’s general and special damages in an amount to be proven at 14
15 trial by jury;
16 b) For Plaintiff’s incurred costs together with interest at the highest lawful rate
17 on the total amount of all sums awarded from the date of judgment until paid; 18 c) For the fair and reasonable monetary value of Plaintiff’s past, present, and 19 future pain and suffering in an amount to be proven at trial by jury; 20 d) For the medical expenses incurred up to the date of trial and any additional 21
22 expenses necessary for future medical care and treatment;
23 e) Economic damages in the form of out of pocket expenses, lost earnings, and
24 other economic damages in an amount to be determine at trial of this action;
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1 f) For punitive damages or exemplary damages to be set by a jury in an amount
2 sufficient to punish Defendant for his outrageous conduct and to make an example of him 3 so that others do not engage in similar conduct in the future; 4 g) Costs including reasonable attorneys’ fees and costs, court costs, and other 5 litigation expenses; and 6
7 h) For such other and further relief as this Court may deem just and proper.
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9 Dated this 18th of November, 2020.
10 /s/ David Matthew Haynie 11 David Matthew Haynie
12 /s/ Ashley Pileika Ashley Pileika 13 /s/ Damon J. Baldone 14 Damon J. Baldone 15 Attorneys for Plaintiff Jane Doe 16
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