FIRST JUDICIAL DISTRICT OF MARC 1 mm 55011112}: IDENTIHCATION NO. 55271 4951 OXFORD AVENUE PHD-ADM PA 19124 (215) 5355900 may/mm 11c! "10me FOR PLAINTIFF ASHLEY STAMMNORTHUP DANICA DILLON .kmnfi' vs. JOSHUA JAMES DUGGAR JOSH DUGGAR Delmdm COURT OF COMMON PLEAS 0F PHILADELPHIAIM "Land by PRorHouaru1 17 um; 21:15 03:52 pm 12. 5mm: COURT OF COMMON YLEAS COUNTY, OF CIVIL DIVISION ~10 NOTICE TO DEFEND NOTICE Yan hm been and in mun. yun Io defend mm: mam for": 1.. mum puts, you man an mm mm twenty m) ma mi; complaint ".41 mm 1" served. by entering . "men .ppemm personally or by .mmy and filing in writing with an mun yum defame: or obimmx In 111: damn (uni: ugh-n you. You An :11. > a la ofiu'm cwya flincdan :5 menu" said Abuja pm wrrl'gwu dunksepule musth mum-'1: Ancilclon De Licentiadas De Servicio De "Head: 1: lnfomaciun Legal 011: Ruding Cum Filadglfia, 19107 (215) 1386333 (215) 61-6197 Case ID: 151102503 MARC J. FRUMER. ESQUIRE IDENTIFICATION NO: 55271 4961 OXFORD AVENUE PHILADELPHIA, PA 19124 (215) 53576900 ATTORNEY FOR PLAINTIFF ASHLEY COURT OF COMMON PLEAS COUNTY OF PHILADELPHIA CIVIL DIVISION Plainnff TERM NO. JOSHUA JAMES DUGGAR AK A JOSH DUGGAR De fendanl -- CIVIL ACTION 1 Immducnon. 1. Plamtirf. Ashley age 28. DOB, January 4. 1937. Is a mamed mother cfmo mull chl1dren She a resident ot'San Dmgo. Cahfomm PlamuflW: also known 21> Danica Dullon. 2, Defendant. Joshua James Duggcn age 17.0.13 March 3. 1988. 15 a residem cf Reformer's Unanimous Men's School of Diccipleshxp Rockford. Defendant IS 41150 known as Iosh Duggar, Case ID: 151102503 11. Defendant committed a battery upon the Plaintiff twice. 3. All previous paragraphs are incorporated herein. 4. Defendant approached Plaintiff, on or about March 12, 13, 14, 2015, at The Gold Club, a ?gentlemen?s clu and bar, located at 1416 Chancellor Street in Philadelphia, additionally, on or about April 17 18, 2015, at the Creekside Cabaret. 5. Plaintiff was the featured performer at The Gold Club on this particular evening. Plaintiff is a movie actress in both adult and mainstream films. Plaintiff is also a model and spokesperson for several companies. Her employment includes making public appearances as well as acting. On this particular night she was the featured performer and was advertised as such. 6. During her appearance, Defendant requested Plaintiff for several ?lap dances? for which he paid the club approximately $600. 7. After her performance at The Gold Club, Defendant continued to pursue Plaintiff, following her to the DoubleTree Hotel where she was staying. 8. Defendant then propositioned Plaintiff for consensual sex. Defendant paid Plaintiff $1,500 for her company. 9. Once inside the Plaintiff 5 hotel room, Defendant manhandled Plaintiff and physically assaulted her to the point of causing her physical and emotional injuries. Indeed, Plaintiff felt as if she were being raped by the Defendant. This was not part of any agreement and clearly exceeded the scope of any consent by the Plaintiff. 10. Defendant intended to cause such harmful and offensive contact with the Plaintiff and directly, through his tortious actions and conduct caused Plaintiff to suffer severe emotional and physical injuries. Case ID: 151102503 . Defendant subsequently attempted to ?apologize? for the tortious battery he in?icted upon the Plaintiff. This apology occurred at the Creekside Cabaret. However, his motive for his ?apology? was to deceive Plaintiff into another private meeting with her Where he engaged in identical tortious conduct causing Plaintiff to suffer severe emotional and physical damages. 12. As a direct result of Defendant?s actions, Plaintiff has suffered serious emotional and physical damages. She is currently being treated by a for severe anxiety, similar to post- traumatic stress disorder and has suffered physical injuries as well. Further, Plaintiff has been unable to work in her chosen field as a direct consequence of Defendant?s actions. WHEREFORE, Plaintiff demands that Defendant be found liable for intentional battery of Plaintiff and requests damages in excess of $500,000 be imposed upon Defendant. Defendant caused intentional emotional distress via his outrageous tortious conduct upon Plaintiff. 13. All previous paragraphs are incorporated herein. 14. As previously stated above, Defendant engaged in violent and outrageous conduct causing severe emotional distress to Plaintiff. Plaintiff has suffered severe emotional and physical injuries due to Defendant?s violent and outrageous conduct. 1 5. As a direct result of Defendant? actions, Plaintiff has suffered considerable emotional and physical damages. Plaintiff is currently being treated for severe anxiety similar to PTSD by a due to Defendant?s violent and outrageous conduct. Further, Plaintiff has been unable to work in her chosen ?eld as a direct consequence of Defendant?s actions. Case ID: 151102503 WHEREFORE, Plaintiff demands that Defendant be found liable for intentional in?iction of emotional distress due to his outrageous and Violent conduct towards Plaintiff and further, Plaintiff requests damages in excess of $500,000 be imposed upon Defendant. Respectfully submitted, ll 5W, \p?unat WC J. ESQUIRE Counsel for Plai iff Ashley Stamm-Northup Case ID: 151102503 VERIFICATION The undersigned veri?es that the statements made in the foregoing pleading are true and correct to the best of his belief and understands that false statements herein are made subject to the penalties of 18 4904, relating to unsworn falsi?cation to authorities. ., f~ 245/ [1.44- l] ,7 . Date: Ni?: U: MARC J. ESQUIRE Case ID: 151102503