OBrien_v_Spence

CASE NO. _

_

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION

CATHLEEN ANN O’BRIEN,
individually and as next friend for her daughter
KELLY LYNN COX,

Plaintiffs,

v.

CRAIG J. SPENCE,
RALPH VITTI a/k/a MICHAEL DANTE,
RONALD REAGAN,
RICHARD “DICK” CHENEY,
and JOHN DOES 1–10 (additional high-ranking political officials and co-conspirators whose identities are known to Defendants and who participated in the acts described herein),

Defendants.

COMPLAINT

Plaintiffs Cathleen Ann O’Brien, individually and as next friend for her daughter Kelly Lynn Cox, by and through their undersigned counsel, complain of Defendants and respectfully show the Court as follows:

I. JURISDICTION AND VENUE

1. This Court has subject-matter jurisdiction over this action pursuant to D.C. Code § 11-921 and the general civil jurisdiction of the Superior Court of the District of Columbia, as the claims arise from tortious acts occurring within the District of Columbia.

2. Venue is proper in the District of Columbia pursuant to D.C. Superior Court Civil Rule 3 because a substantial part of the events or omissions giving rise to the claims occurred in Washington, D.C., specifically at the White House and related government and private locations within the District.

3. Defendants are subject to the jurisdiction of this Court because they purposefully availed themselves of the privilege of conducting activities within the District of Columbia by attending and participating in official political events at the White House and related venues, where they engaged in the unlawful conduct described below.

II. PARTIES

4. Plaintiff Cathleen Ann O’Brien is an individual who resides in the United States and was, at all times relevant herein (approximately 1982–1988), an adult subjected to repeated coercion and abuse while under the influence of high-ranking political officials.

5. Plaintiff Kelly Lynn Cox was, at all times relevant herein, a minor child (approximately ages 5–11) and was subjected to sexual abuse while under the control and direction of her mother and the Defendants.

6. Defendant Craig J. Spence was a prominent Washington, D.C., lobbyist and political operative who participated in events at the White House and related locations, where he facilitated and engaged in the sexual exploitation of Plaintiffs.

7. Defendant Ralph Vitti a/k/a Michael Dante was a known associate of high-level political figures and participated in events at the White House and related locations, where he engaged in the sexual exploitation, pornography production, and abuse of Plaintiffs.

8. Defendant Ronald Reagan was President of the United States and participated in events at the White House, where he directly engaged in the sexual abuse of Plaintiff Cathleen Ann O’Brien.

9. Defendant Richard “Dick” Cheney was White House Chief of Staff (and later held other high-level positions) and participated in events at the White House, where he directly engaged in the sexual abuse of Plaintiff Cathleen Ann O’Brien.

10. John Does 1–10 are additional high-ranking political officials, aides, and co-conspirators who facilitated or participated in the abuses at the White House and related D.C. locations and whose identities will be ascertained through discovery.

III. FACTUAL ALLEGATIONS

11. Between approximately 1982 and 1988, Plaintiff Cathleen Ann O’Brien was solicited and coerced by high-ranking political officials, including the named Defendants, who used their positions of seniority and authority to position her for unwarranted sexual acts at the White House and related locations in Washington, D.C. These officials exploited their influence to direct her attendance at official and private events, where she was subjected to multiple sexual assaults, including gang rapes, and was pimped out to other political figures for their sexual gratification.

12. Plaintiff Cathleen Ann O’Brien was also exposed to environments involving drug-induced situations as part of the coercion, further impairing her ability to resist the demands of these officials.

13. During the same period, Plaintiff Cathleen Ann O’Brien was directed by these officials to bring her minor daughter, Kelly Lynn Cox, to certain White House and related events. At these locations, Kelly Lynn Cox was taken and subjected to sexual abuse by the Defendants and their associates.

14. The acts were committed without consent and involved harmful and offensive sexual touching, penetration, and other forms of exploitation. Defendants acted in concert with one another to conceal these crimes through threats, manipulation of Plaintiffs’ circumstances, and exploitation of their positions of power.

15. These events occurred entirely within the District of Columbia and caused Plaintiffs severe, permanent physical and emotional harm, including profound psychological trauma, dissociative disorders, chronic pain, and long-term damage to their health and well-being.

IV. CAUSES OF ACTION

COUNT I – SEXUAL BATTERY AND ASSAULT
(Against All Defendants)
16. Defendants intentionally and unlawfully touched Plaintiffs in a harmful and offensive manner, including sexual penetration and other sexual acts, without consent.
17. As a direct and proximate result, Plaintiffs suffered severe physical injury, emotional distress, and long-term psychological harm.

COUNT II – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(Against All Defendants)
18. Defendants’ conduct was extreme and outrageous, exceeding all bounds of decency, and was undertaken with the intent to cause, or with reckless disregard of the probability of causing, severe emotional distress.
19. Plaintiffs have in fact suffered severe emotional distress, including but not limited to dissociative disorders, suicidal ideation, and permanent psychological damage.

COUNT III – FALSE IMPRISONMENT AND COERCIVE CONTROL
(Against All Defendants)
20. Defendants unlawfully restrained Plaintiffs’ liberty through physical force, threats, coercion by senior political officials, and exploitation of their positions of authority, holding them in a state of involuntary servitude in the District of Columbia for purposes of sexual exploitation.
21. Plaintiffs were deprived of their freedom of movement and autonomy as a direct result of Defendants’ actions.

V. PRAYER FOR RELIEF
WHEREFORE, Plaintiffs respectfully pray for judgment against Defendants, jointly and severally, as follows:

A. Compensatory damages in an amount to be proven at trial, but not less than $50,000,000.00;
B. Punitive and exemplary damages in an amount sufficient to punish Defendants and deter future misconduct;
C. Pre- and post-judgment interest at the maximum legal rate;
D. Costs, attorneys’ fees, and expenses as allowed by law;
E. Such other and further relief as this Court deems just and proper.

Plaintiffs demand a trial by jury on all issues so triable.

Respectfully submitted,