is entitled to a massage. Because she had not received a massage for a couple of
months, on June 3, 2013, she asked that she receive an extended massage.

8. After removing her clothes and lying on her back on the massage table, Jane Doe
101 covered herself with a sheet in preparation for the massage. The massage began
uneventfully. However, unlike all prior massages, Ster never told her to turn over so that he
could massage her back.

9. During the last few minutes of the massage as Jane Doe 101 was lying on her back on
the massage table, Defendant STER ran his hand down her chest and between her breasts,
thereby removing the sheet covering her body. STER then ran both of his hands over Jane Doe
lOl's breasts, with one hand continuing down her body to her vaginal area. STER kept his hand
on Jane Doe 101's vaginal area as he moved down the massage table and began to perform oral
sex on her vagina and clitoris. Like most sexual battery victims who are assaulted during a
massage, Jane Doe 101 was in complete shock, initially froze, and did not know what to do.
Jane Doe 101 then pushed STER's head away from her vagina. STER paused momentarily, then
mounted the table and was kneeling above Jane Doe 101 on the table when he started to perform
oral sex on her vagina and clitoris again. At that time he also digitally penetrated her with his
?nger. Jane Doe 101 continued to try to push head away from her vagina. This lasted
one to two minutes before STER stopped, got off of her, and told her the massage was over.

10. MASSAGE ENVY is a national franchise, based in Scottsdale, Arizona. MAS SAGE
ENVY has over 900 locations in 48 states and has more than 1.25 million members.

11. MASSAGE ENVY also has a big problem. The problem is the sheer number of acts
of sexual battery, sexual assaults, acts of sexual malfeasance, and acts of sexual misconduct

committed nationwide by its male massage therapists upon female clients.