CAUSE NO. _redacted, 50_


SASCHA BARROS,

Plaintiff,


v.


WILLIAM RILEY (a/k/a William Kyle Riley),
PAUL RILEY,
STEVE KIRALY,
and JOHN DOES 1–10 (Co-conspirators whose identities are known to Defendants and who participated in the acts described herein),

Defendants.


IN THE CIRCUIT COURT OF THE _redacted, 50_ JUDICIAL CIRCUIT
IN AND FOR _redacted, 100_ COUNTY, FLORIDA


PLAINTIFF’S ORIGINAL COMPLAINT


TO THE HONORABLE JUDGE:


Plaintiff Sascha Barros (also known as William Sasha Riley) complains of Defendants William Riley (a/k/a William Kyle Riley), Paul Riley, Steve Kiraly, and DOES 1–10, and respectfully shows the Court as follows:


I. PARTIES
1. Plaintiff Sascha Barros is an adult resident of the United States who was a minor child from approximately 1978 through 1989.
2. Defendant William Riley (a/k/a William Kyle Riley) is an individual who adopted Plaintiff and served as his primary handler and trafficker.
3. Defendants Paul Riley and Steve Kiraly are individuals who acted as associates and co-conspirators with William Riley.
4. All Defendants are known members and/or associates of the Dixie Mafia, an organized criminal enterprise engaged in arms trafficking, drug trafficking, and child sex trafficking throughout the Southeast United States, with documented operations in Texas, Tennessee, Alabama, and Florida.


II. JURISDICTION AND VENUE
5. This Court has subject-matter jurisdiction because the amount in controversy exceeds the jurisdictional minimum and the claims arise under Florida law.
6. Venue is proper in this County because a substantial part of the events giving rise to the claims—including grooming, prostitution, filming, illegal fighting, and an attempted murder by drowning—occurred in Florida. Fla. Stat. § 47.011.


III. FACTS
7. From 1978 through 1989, Defendants, operating within the Dixie Mafia framework, systematically groomed and exploited Plaintiff, a minor child, for profit and control. Immediately after adoption, Defendants began conditioning Plaintiff to serve as a sex object.
8. Starting at approximately age 6, Defendants prostituted Plaintiff in pay-for-sex transactions, with all proceeds directed to William Riley as handler.
9. Beginning at approximately age 6, Defendants forced Plaintiff to perform sexual acts in illegal pedophilia films that were produced and distributed for profit within the Dixie Mafia network.
10. Beginning at approximately age 10, Defendants forced Plaintiff into no-gloves, bloody-knuckle fist-fighting competitions for illegal gambling and pay-for-view purposes.
11. Defendants’ co-conspirator Mary Lynn Riley (deceased) actively managed a brothel of underage girls, including Samantha, Patricia, and Sarah—all three of whom were later murdered. Mary Lynn Riley was complicit in every aspect of the exploitation and was described by Plaintiff as “evil” for her sadistic treatment of the girls, whom she regarded as servants or slaves.
12. In Florida, Defendants attempted to murder Plaintiff by luring him into a riptide zone at the beach (Panama City/Destin area) and leaving him to drown. A civilian rescuer intervened, generating a police report and investigation that was later stalled.
13. Defendants repeatedly interfered with investigations, including multiple CPS referrals and police reports in Florida, to conceal their criminal enterprise.
14. The entire pattern of conduct was part of an organized Dixie Mafia racketeering activity involving child sex trafficking, pornography production, illegal gambling, and violence. Plaintiff suffered severe physical injuries, lifelong psychological trauma (complex PTSD, dissociation, hypervigilance), permanent emotional harm, and economic losses directly caused by Defendants’ actions.
15. A child should never have been subjected to any of these activities; the entire scheme was inherently unfair, exploitative, and illegal.


IV. CAUSES OF ACTION


Count 1 – Sexual Battery of a Minor (Fla. Stat. § 794.011 & common law)
Defendants intentionally subjected Plaintiff, a child under 16, to sexual battery, prostitution, and forced filming.


Count 2 – Battery
Defendants committed harmful and offensive physical contact through forced fighting, beatings, and the Florida drowning attempt.


Count 3 – Intentional Infliction of Emotional Distress
Defendants’ extreme and outrageous conduct—systematic grooming, trafficking, filming, forced fighting, and attempted murder—caused severe emotional distress no reasonable person should endure.


Count 4 – Civil Conspiracy
Defendants conspired with each other and with Mary Lynn Riley to commit the above torts and racketeering acts for profit.


Count 5 – Florida RICO (Fla. Stat. § 895.05)
Defendants participated in a pattern of racketeering activity (child sex trafficking, prostitution, pornography production, illegal gambling) that injured Plaintiff. Plaintiff is entitled to treble damages.


V. DAMAGES
Plaintiff seeks:
• Actual damages (physical pain, mental anguish, medical/psychological care, lost earnings, physical impairment);
• Treble damages under RICO;
• Punitive damages;
• Pre- and post-judgment interest;
• Costs and attorneys’ fees; and
• All other relief to which Plaintiff is entitled.


VI. STATUTE OF LIMITATIONS All claims are timely. There is no statute of limitations for civil actions based on sexual battery of a victim under age 16 (Fla. Stat. § 95.11(9)/(10)). The profound trauma, ongoing threats, and Defendants’ cover-ups prevented earlier filing.


PRAYER WHEREFORE, Plaintiff Sascha Barros prays for judgment against Defendants, jointly and severally, for all damages, treble damages, punitive damages, interest, costs, fees, and any further relief the Court deems just.


Respectfully submitted,

redacted


ATTORNEY FOR PLAINTIFF