INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 SUPREME COURT NEW YORK OF THE STATE OF NEW YORK COUNTY X ----------------------------------------------------------------------X JULIE PARKER, AMENDED COMPLAINT Plaintiff, - against HOWARD Hon. Doris Ling-Cohan Index No. 0650126/2018 - RUBIN, Defendants. X ----------------------------------------------------------------------X Plaintiff PC, for as and Parker Julie "Defendant" "Defendant"), her Amended ("Plaintiff" Complaint, or "Ms. Parker" Parker"), against Defendant The Defendant instant case Howard involves a brutal Plaintiff 3. Defendant Portfolio 4. New Julie A Parker substantial at Soros part Fund of the and Julie gruesome Group, or AND of New Management, events in Los residing is a resident LLC, rise giving of acts sexual abuse, committed by Parker. JURISDICTION is an individual Rubin Howard Managers ("Rubin" Rubin Howard Landau STATEMENT rape, Plaintiff against Rubin, PARTIES, 2. The attorneys, as follows: alleges, PRELIMINARY 1. her by York, located VENUE California. Angeles, New and York, in New York, claim occurred to Plaintiff's was New of the one top York. in the County of York. 5. Venue 6. This is therefore Court proper has jurisdiction in this pursuant Court pursuant to CPLR STATEMENT OF to CPLR 503(a). 301. FACTS 1 11 of 19 of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. On or before 7. Minton November while ("Minton"), Plaintiff 8. and RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 her sent 9. this New visiting exchanged text to a person introduced York City. messages, and Minton correspondence, to dinner out was was Plaintiff named Minton told Nicole about herself, photos. During to go she Minton and Plaintiff 3, 2015, and with drinks, Plaintiff informed a wealthy man, but that that she she would would not be paid $2,000.00 be required to have sex. On or about 10. to visit City, Plaintiff Tea that Room, New York 13. she she Minton 4, 2015, be meeting 5, 2015, Plaintiff's at, and located Parker on November New York a guy Plaintiff sent "Howie" named a text for lunch which message, at the tomorrow, instructed Russian Plaintiff and her arrival in New from travelled friend, DC back Washington to at 157 was 57* W. told information The nice 16. When host for prepared by her she York, with date her deposited Defendant Rubin, luggage at the at the Russian apartment Tea Room in Street. Minton to arrive at the Russian Team Room at, or around, 2pm, 5, 2015. a really the would after staying 14. Ms. by from DC, City. Manhattan, with to Washington travelled in Manhattan. Shortly was 15. of November night On November 12. Plaintiff 4, 2015, a friend. On the 11. November Ms. to their Plaintiff guy in his Parker reserved 40's arrived, received that went Defendant regarding by the Rubin Rubin, name was was that she would be having lunch "Howie." not yet there, as such, she was escorted table. 2 2 19 2 of of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 Rubin 17. Defendant from their neat. A 18. which waiter, food and hours 20. 22. appeared for in the Parker had Ms. Parker talked of Don alcoholic 1942 Julio drinks Anejo, volume). by in conversation, Both "comfortable". of round and Rubin Defendant continuously and Parker Ms. ordered restaurant. multiple alcoholic over drinks the of course a baseball and Ms. nice well if he liked that that he had Parker got along who was an hour, interests game person, over Plaintiff's to Plaintiff indicated or basketball Rubin and wealth, for floor well and in the ambitions to go fly her things, to college. to Miami to to. of beginning in talking interested other among he would her, seats about, their to Ms. and date, Parker, he and getting and relax. her. 23. their During Parker asked alcohol Parker Ms. Ms. and to be a genuinely to know Ms. and Rubin Defendant get 40% first 2 glasses was belief, (or engaged beverages lifestyle Defendant some and and their and caviar, restaurant. Rubin's 21. Rubin and Rubin Defendant Defendant watch at the expensive is 80 proof that alcoholic Rubin 19. Defendant couple tequila "more" to drink some information Defendant Thereafter, additional upon expensive very her asked ordered for and complied, any than more date, was served and identification, after continued accordingly both her, to insist by and the that Russian Defendant Ms. Tea Rubin Parker Room, had been drink without once at the being restaurant an hour. 24. Plaintiff was 25. At some point, and presented restaurant, Rubin Defendant just 20 during years their Plaintiff old. date, with Defendant Rubin's a non-disclosure assistant agreement 'Stephanie', came into the ("NDA"). 3 3 19 of 3 of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. 26. to RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 NDA The if she $1,000,000, 27. Parker Ms. whereupon 28. Rubin interested in her, were the the counsel Parker Ms. such, with Parker adult, or even included, Stephanie thought good an intoxicated, that to the was had document. Parker Ms. and a business. in the seemed this an NDA, process simply decision made by about to transpire. was never and promptly and genuine, was was up disclose to sign kids, that for sued Parker. already and horrible not who impromptu something could required man, life, be Ms. women, wealthy could she and married, intoxicated, of the promises that she why he was a young, Parker Ms. Rubin Defendant an extraordinary with signature which because It was the her affixed and was by wealthy. that between required seduced, indicated NDA, Rubin it was Ms. as a caring done legal that and the occurred Defendant is 20/20. manipulated, of terms which stated of being without the asked Hindsight things broke Rubin Defendant by or conduct activities any presented given how Plaintiff As of a copy NDA. After signing 30. After Stephanie 31. Defendant 29. the Stephanie NDA, it from grabbed Plaintiff, left the restaurant. in the apartment, door next 32. was. and to the had a book Rubin that Ms. and Parker and ultra-expensive Russian Tea Room. Rubin Rubin brought told Plaintiff lavish, Defendant Further, left, them he kept, told Ms. explained up with to his their that Defendant more his about he had dated his where apartment, in it. Further, Tower, apartment, famous many and wealth, Metropolitan Parker pictures about he took Rubin with continued Rubin, and how explained with lunch he owned which models, pictures that their the he explained lavish, and that in and penthouse was right beautiful and it playmates, Playboy them, date. had addition them sign to this 4 44 of 19 of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. that book, on the book of his of the Plaintiff 35. Upon 76' 76 Rubin then women and of the Rubin 37. Defendant Rubin's 38. Defendant Rubin was the Further, other and 40. few Rubin famous began now within he wanted 42. people never seen into his fact of pictures were and he hung was book her with the of next penthouse Tea his to show door. apartment, Room. to his up decorated apartment. in a modern her around. and playmates, style. While a cocktail. famous models, model respective large the elevator began and apartment Russian to the and apartment, would. to his the fixed with she beautifully the decorated went took and Rubin Rubin that door apartment, Plaintiff show to see his apartment next large, very Defendant apartment, apartment to drink light that Defendant 10 to up before with, and in her cocktail headed 15 minutes her room toy the to feel to show Rubin's to tie was and drinks, inside, like Rubin told located Parker Parker contained began it is evident that that Playmates, or playmate. of playboy photographs he playmates, models. Plaintiff Next, and models, would Rubin's Tower, Ms. in their Defendant belief, Ms. did of his walls minutes, 41. led if she Parker Ms. up apartment the which about, dated. finished walked admiring Defendant her told of these some Parker Ms. Metropolitan Defendant 39. then information 36. Plaintiff asked he had Rubin and Floor, of photographs apartment. famous 34. large very Defendant the but he had walls 33. on RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 his was "toy a small electrocuting fixed by her body and Rubin of drugged consuming as he Rubin, fatigued. At the Plaintiff's drink. the Defendant drink, her showed time after around, and was disoriented, she Rubin told Ms. a Parker room." - around 200-300 devices, and square other foot devices - and room, things with that ropes and Ms. Parker toys had life. 5 5 19 of 5 of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. Plaintiff 43. into RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 these was had a safe got uncomfortable, 45. word: Rubin secure, and At point, this then increased tight, 49. Plaintiff she the that Rubin instructed Ms. Parker's and clothed, fully up Parker she that he was on her, and easy Plaintiff to say pineapples in ropes, while she that if she not that Plaintiff's she was. so they wrists, to any were relinquish to totally consented still was face. explained Plaintiff forcing had go on the around ropes, and power, her fun". he would and this, of the told her. Ms. with "for wrists slapped okay of the for and her, wrists, explained much gently was her up too resistance all still was her the most down, hellish encounter Plaintiff Once took defenses a much 50. Ms. 51. Rubin was darker Parker yelled then then Parker to grimace in pain. Defendant Rubin 52. grabbed enraged her body, fully while and of her and restrained, smacked Ms. incensed - and to clamp other control. physical or vulnerable completely Parker for her on Rubin blouse Parker's her face, off, nipples even harder, caused him to start punching and smacking by ropes Rubin, he hard. really began and nipples, Parker's restrained to Defendant hanging her breasts, pulling hard, to expose Ms. was Parker Ms. to stop. pulled Plaintiff to put proceeded, life. and ripped Ms. Rubin intoxicated, young "PINEAPPLES' a device him, and drugged, and turn, became Rubin over if Rubin giving With through which then assured contact. 48. then Plaintiff tied lightly Rubin asked and became then Defendant Rubin 47. sexual Rubin tie lightly Defendant anything Rubin but saw, to do this, PINEAPPLES. Defendant 46. she if he could Rubin or if clothed. what by asked allowed she fully and things, Plaintiff 44. startled from and she begged Plaintiff with this predator's whereupon Ms. causing him his to stop, fists, all ceiling. 6 66 of 19 of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. 53. Rubin's worse Rubin 58. from being did each Ms. agony and Parker begged him and pain, and begged the cried, Rubin to stop worse Defendant his the tied Rubin and begged her he called Plaintiff that with uses and for cried him just toys, like names, appalling was different criminal her by Parker Ms. in the of the and insides, grabbed he held whereupon, repeated brutal foregoing and she to stop, the game. thereafter, shortly her ripping up, sadistic saying Parker more as bad as the extensive causing she was other a whores. and bruising body. to stop anus Ms. the Plaintiff, he kept to beat her that and prodded and warning, Parker After more Parker Ms. and continued for in crying a horrifying a whore, Without ground; and beat throughout pleas Ms. and told playing Rubin shit, swelling, 57. get; While of the however, go, Rubin Defendant 55. 56. her and screaming became. it would piece was to let abuse 54. up Parker Ms. and abuse, and RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 the her causing sexual acts, back of her and down, word" "safe of middle - Plaintiff's Rubin for screams shoved a big mercy, Black dildo to bleed. Defendant hair started and Rubin then smashed her more shoving released face things Parker Ms. into the of her inside anus vagina. 59. Through not stop, the and veil instead of tears, he got Ms. Parker and worse, begged the Rubin torture once inflicted again to stop; upon Ms. and that Rubin however, Parker got worse with plea. 60. to stop Defendant the more Rubin hurt she told Ms. was going Parker that she "deserved it", the more she asked him to get. 7 77 of 19 of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. 61. Rubin dragged couch, and Defendant her threw RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 her around his while neck, When 62. couch over to the 63. When 64. Ms. 65. Defendant and Rubin then was about flipped her body he told concluded, her without Rubin her by penetrated her he raped Defendant ground Parker Ms. hair with of his outside his penis and his semen, "toy" dungeon-like her choked with room, his hands a condom. to ejaculate over and ejaculate Parker Ms. that semen his she he pulled was on her "whore" a Parker Ms. face and off and the breasts. "clean" to herself up. Parker had to go 67. whereby 68. friend shaking, 70. she his went her When anxious Following professional beaten stability and who then and back was belongings and this were back incident, however, began her car to fall penetrated she like and was downstairs. to the apartment Ms. her Parker for scared and down, like her life. a in pain, wreathed crying again. and apartment, left staying her called calm to see her of his and crying, her informed that he to leave. clothes, she and while out and meet in a panicked future, dinner apartment and shaken, to try he would Parker Ms. gathered in the drink that for kids battered, experience", kicked to the got another Plaintiff promptly Plaintiff her raped, a "pleasurable told wife Plaintiff While emotional even Parker to get 69. her meet Ms. for Rubin Defendant beaten, offered her Rubin hysterically. drugged, Rubin thanked sociopath, 66. was Rubin's was as fast as she could, at.. friend, she place and screaming at, she staying crying, was and her asked upset, noticeably state. Plaintiff in college, enrolled Ms. following apart in with foreign a way Parker's not and experience uncommon objects thrust began with inside attending classes towards and with Rubin, her other victims who of them without life are raped, consent. 8 88 of 19 of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. 71. RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 Parker Ms. memories she 72. was to drink constantly on a daily to compose control or of 73. Ms. her experienced felt rate, the drugs would of onset sweating, in an attempt to forget and attacks, pain the and encounter. intense Plaintiff school, she heart friends to get 74. from take anxiety sneak oftentimes fear extreme and trembling, panic off to the or discomfort, almost and which a fear always and bathroom, commonly of losing dying. Plaintiff's needed At when an accelerated included, Plaintiff basis. herself, and excessively experiencing in 2016, Beginning depression, try began treatment and Parker's professional witnessed her dire situation was and becoming, her told that she to rehab. with experience emotional and go how as well life, Rubin Defendant as her all effected with to interact ability of her aspects the world, physical, and the people in it. Soon 75. Plaintiff 76. had she attacks, depression, room, 79. lived Further, that she In 2016, been an active volunteered sadness, keeps close Plaintiff and and of this in a constant as a result Plaintiff college, as a result However, because 78. began she had and committee, 77. after traveled of anxiety, of this by tried her good fear, and to commit to third world and Plaintiff while to continue, in high Parker she suicide, and on school, dropped out of school. an anti-bullying countries. could experienced not always a daily keeps her continue education college substance nightmares, on powerlessness, incident, bed, unable student Ms. incident, state was abuse, panic basis. some sort of weapon in her sleeps. and ended up in a hospital as a result of a drug overdose. 9 99 of 19 of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. Rubin 80. take only to Bali, and peace, 82. her this time, with did return to deal with, this she young Asian the woman which and BY VICTIM ACTION AND OFFENSES she person can will AND §130.50; be AGGRAVATED Plaintiff (By Plaintiff 1 through paragraphs 83 of this and will OF LAW §130.35, As set forth more Penal Law §130.35(1) fully and yoga, the require a great deal likely, for a one to find inner this has the or around horrific of October experiences treatment, therapy, the of her rest life. ONE CONSTITUTING § 213-C: SEXUAL ACTS SEXUAL CERTAIN FOR ABUSE RAPE VIOLATION IN IN VIOLATION OF PENAL IN VIOLATION OF PENAL §130.70 Howard Defendant LAW of he engaged each reference by as though acts on immersion, TO CPLR RUBIN'S PENAL because and thereafter, to endure, incorporates Complaint above, mediation ACTION Against DEFENDANT PENAL in an attempt yoga SEXUAL Parker repleads repeats, and forced CRIMINAL §130.35; on to Asia, travelling retreat, 5 months retreat LAW under A apart. abuse. roughly CONDUCT OF - left yoga learned through PURSUANT ACTS LAW PENAL LAW 85. fall experienced. US for to the from benefitted put trauma substance Plaintiff exploration, the not and CAUSE 84. and down, and an intensive into depression of a decision made herself throwing anxiety, Rubin Defendant OF to break girl, young Plaintiff 2017, period to cope Although 2017. and this Plaintiff 83. May her treat During helped caused so much. ticket and Plaintiff raping On or around 81. way RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 set forth in full §130.50, Defendant in sexual and every allegation of herein. OF VIOLATIONS AND Rubin) LAW PENAL Rubin intercourse against with §130.70 Plaintiff Plaintiff was by rape forcible compulsion. 10 10 19 of 10 of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. 86. RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 set forth As sexual act(s) in anal sexual 87. As in the Plaintiff by while was visibly upset of of Rubin Defendant engaged intruded into Law her causing Plaintiff's anus and he inserted physical injury. Plaintiff was because Rubin against §130.70(1), compulsion, was because her causing Rubin Penal Plaintiff against §130.70(1), Defendant under forcible Law Penal compulsion, acts by Rubin Defendant forcible degree, - punched her physical inserted injury. - sexual vagina a which organs, or device Plaintiff's vagina severe and and bruising pain, tore and first while arms, with then pinning her body and inserting his penis Rubin Defendant however, resistance any off and criminal constitute where, degree, from anus, pain, overcame ground, and also in the face, the to "STOP", superior his against the into her in the first did size hard not and back of a Plaintiff vagina. shaking. acts abuse to a pole in the into and Rubin's sexual and shoulders crying Rubin Defendant Plaintiff, face her Defendant up told her restraining Plaintiff causing forcibly to rape throwing aggravated extensive first criminal were compulsion. under the above, anus, repeatedly continued sofa into by because §130.50(1), Plaintiff against a rape. strength 91. vagina, Plaintiff's Rubin Defendant and stop into degree, in the Law acts first fully abuse object constitutes in the more the Rubin Defendant forcible by above, of acts Penal Plaintiff Plaintiff's sexual a foreign 90. into under fully abuse set forth aggravated 89. more sexual As with the above, fully degree, conduct object 88. first set forth aggravated foreign more the clothes, and whipped stuck Defendant and her with on her clamps Rubin did a large paddles nipples, the so she dildo, across which foregoing, degree, could and her other he turned Plaintiff not body, and Rubin Defendant things, room" "toy inserted acts other among in his ceiling her sexual escape, foreign tied and objects causing and screamed tightened and 11 11 19 11 of of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 begged Defendant begged him fact it did Parker told worse and more get Plaintiff also sustained by, among and things, inserting and Plaintiff days has injuries, as a result bruising throughout distress, anxiety pain extreme actions and attacks, she from other her with vagina and a person paddles with her own his into body, which remained when urinating pain pain and devices, into penis, her was". extreme flesh, and anus, she other and Ms. throughout her caused including throughout of in and that bruising Rubin objects, covered pain and her saying shitty Plaintiff to stop, and extensive Defendant beating stick a sharpened how when him asked "whore" including and brutal more she a know injuries, and more her would face, dildos the calling vagina, in the bruising Defendant present, inability continues Rubin's body, suffering, past, fear, and of Defendant depression, humiliation, of like sustained, her major concentrating, and her as bleeding advancement Syndrome, anus worse while physical large felt the so that severe her get grew vagina. her Further, visible for thereafter. Plaintiff professional all Rubin Defendant it would pain the extensive as well after, where brutal, extremely experienced weeks that punching in what vagina, and her from bleeding other repeatedly 93. and through body, several to stop, to go her for to stop, "needed 92. anus Rubin actions, from bleeding and to suffer, educational anxiety, future to trust, powerlessness, anus, pain severe disorder, expenses, with difficulty hopelessness, and enduring not limited when post-traumatic anxiety medical but including, opportunities, depression, generalized and her traumatic urinating, mental stress substance loss of relationships, and damages embarrassment to: substantial wage loss, anguish Rape sleep, and abuse, nightmares, thoughts from of loss of emotional disorder, use and suicide, the Trauma panic and difficulty and reprehensible Rubin. 12 12 19 12 of of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. 94. of RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 The Plaintiff's and of conduct should be assessed against was of and exemplary Rubin Defendant in wanton and intentional, imposition the therefore, rights, Rubin Defendant to punish him and deliberate punitive damages for appalling, such disregard is warranted, and criminal acts. 95. such ratifying and Rubin Defendant thereby willful in willful, and the justifying conscious Actual b. Exemplary c. Attorney Fees, costs, d. For other relief and such and and in Punitive and that in interest, the court CAUSE FRAUD OF Plaintiff 1 through paragraphs 97. set forth As illusion, that 98. This deceive guise it was was Plaintiff, of an NDA, of 96 more to Plaintiff ("NDA") repleads repeats, so that and the above, were he could threat get that away to be he would the by and Court; Rubin) each reference set forth Rubin in had children, Defendant sue Plaintiff and Rubin, sexually for and allegation every millions of herein. a Non-Disclosure at a public married, raping, full presented drinking by with determined TWO by and misrepresentation relief: INDUCMENT Defendant was of Plaintiff, welfare $7,500,000.00; ACTION as though eating conduct, $2,500,000.00; Defendant Rubin because of incorporates Complaint they required a knowing this fully while and despicable proper. THE (Against 96. of an amount IN and safety following excess deems and and/or damages. the in excess Damages in authorizing oppressive rights, exemplary requests damages compensatory of the and/or acts intentional, disregard respectfully a. aforementioned malicious, of punitive award Plaintiff WHEREFORE, in the engaging engaged acts, with acted by Agreement and the a business. which was abusing of under and restaurant, intended her, dollars, under and to the destroy 13 13 19 of 13 of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. her RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 if life, against she breached of what regardless it, reprehensible acts he subsequently committed the purpose her. 99. Rubin therefore to rely upon Defendant Plaintiff inducing 100.A simple wall deep Bears Management, this with refer Merrill of a casual deliberate representations observer the among were to Defendant Portfolio top of false. professional Rubin's Managers at Soros Fund Lynch. it is not NDA such for material his once pedigree, background, presentment that knowing and misrepresentation this would street Stearns, 101.Appreciating associated it, search internet and experience, made difficult to understand to control Rubin, by the and specific manipulate intent Plaintiff's silence. 102. much or support. money 103.As omission of fact, to her 104. The very idea time, ever where 106.As relative in injury there NDA an NDA, to Plaintiff 107.Plaintiff has injuries, as a result bruising throughout stood became is that a matter was you where 105 pounds, the ideal victim Defendant Rubin was not may an was for Rubin's made consent NDA was this induced, fraudulently which and 20 years with and old, not Rubin. misrepresentation or material detriment. ongoing was on relied justifiably of rape 5'5" at Parker, Defendant such, to the Ms. Plaintiff such, 105.If Parker Ms. Juxtaposed, and unenforceable, is that Plaintiff to deceive if ever there was a case. of material misrepresentations knowing intended to it. and induce her present to act on fact it, resulting thereto. sustained, of Defendant her body, and continues Rubin's bleeding to suffer, actions, from her traumatic including, anus, pain but when and not damages enduring limited urinating, to: and substantial wage loss, loss of 14 14 19 14 of of 16 INDEX NO. 650126/2018 INDEX NO. 650126/2018 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 professional advancement distress, pain Trauma Disorder, attacks, generalized nightmares, of and of and extreme be abuse fear, humiliation, of assessed and disorder depression, panic medical expenses, future to trust, inability with difficulty and hopelessness, emotional Rape (PTSD), and anxiety loss of sleep, thoughts relationships, from embarrassment the Rubin. Rubin was of Rubin Defendant in wanton and intentional, imposition the against present powerlessness, Defendant therefore, major anguish stress post-traumatic disorders, past, disorder, of Defendant rights, should and mental severe opportunities, depression, concentrating, conduct Plaintiff's use anxiety actions The anxiety, substance and reprehensible 108. suffering, difficulty suicide, educational and and exemplary to punish him and deliberate punitive damages for appalling, such disregard is warranted, and criminal acts. 109. such ratifying and willful a. Compensatory b. Exemplary c. Attorney d. That e. For Dated: conscious and Fees, the NDA such other New April and in excess Punitive Damages be and declared relief York, that New interest, as void; the court rights, of the oppressive safety and in authorizing and and/or despicable conduct, of Plaintiff, welfare following relief: $2,500,000.00; in excess in and/or damages. exemplary requests damages acts intentional, of the disregard respectfully costs, aforementioned malicious, of punitive award Plaintiff WHEREFORE, in the engaging in willful, and the justifying by engaged acts, with acted thereby Rubin Defendant of an amount $7,500,000.00; to be determined by the Court; and deems proper. York 6, 2018 Respectfully submitted, 15 15 19 of 15 of 16 FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM NYSCEF DOC. NO. 22 NYSCEF 22 DOC. NO. INDEX NO. 650126/2018 INDEX NO. 650126/2018 RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 04/06/2018 THE LANDAU GROUP, PC By: Kevin 45 A. Landau Rockefeller New Plaza, New York, York Suite 2000 10111 537-4025 (212) kevin@thelandaugroup.com for Attorneys Dated: requests New April a trial York, on by jury New Julie Parker DEMAND JURY Plaintiff Plaintiff all issues so triable. York 6, 2018 submitted, Respectfully THE LANDAU GROUP, PC By: Kevin 45 A. Landau Rockefeller New New York, (212) Plaza, York Suite 2000 10111 537-4025 kevin@thelandaugroup.com Attorneys for Plaintiff Julie Parker 16 16 19 of 16 of 16 INDEX NO. 650126/2018 INDEX NO. 65 0 1 2 6 / 2 0 1 8 FILED2. FILED: NEW COUNTY CLERK 04/06/2018 06:29 PM NEW YORK YORK COUNTY CLERK 05/04/2018 09:45 AM NYSCEF DOC. NO. 22 NXSCEMOC. NO. 28 RECEIVED NYSCEF: RECEIVED NYSCEF : 05/04/2018 0 5 / 04/2 018 COURT SUPREME OF STATE THE NEW YORK NEW YORK OF COUNTY PART PRESENT: .....® Dc Justice a y-k NDEX NO. y -v- . i8' ~rot2< MOTION DATE MOTION SEQ. NO. The following Notice papers, numbered of Motion/Order to Show Answering - Affidavits to/for motion No(s). Exhibits No(s). Exhibits ~ /~ it is ordered papers, p i5/7(/C w~~w ;W~d that CI.A M motion this iti i /S F W/ ~ A (c d/b(17/3.5 /o C/+p~~WA7 7S ~~ O 4 ~64 W1 4 7 cg F lJZy Mg~twg~ ~u-M sp~~~Vi, io 0 ~ M~~P<~~< j O IL' 6 - read on this No(s). the foregoing o//SC >- Cause , were Affidavits Replying Upon - Affidavits _ 1 to I 0 g~ ~ / g+~ gr r Q~~ ~w, ~~ I : ,f p { (.x.o reFZecg' 1. CHECK ONE: ..................................................................... 2. CHECK AS APPROPRIATE: 3. CHECK IF APPROPRIATE: ...........................MOTION ................................................ c.icosi + +~~ +~+ 7 /ce QM 8~ v/ Date J vf/6'c/ IS: Shef../dMa Duo> >~ O CASE ¤ GRANTED O SETTLE J d , J.S.C. M DISPOSED ¤ DENIED 171 of 19 of 3 GRANTED ¤ ORDER DO NOT POST O O FIDUCIARY DISPOSITION NON-FJNAI.. ¤ IN PART SUBMIT APPOINTMENT OTHER ORDER ¤ REFERENCE INDEX NO. INDEX NO. 650126/2018 65012)/21118 01 650126/ NO. INDEX RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 05/04/2018 : 03/19/20iu SC I RE NEW YORK FI.: YORK T FILED: NEW COUNTY CLERK 04/06/2018 06:29 PM CO NYSCEF DOC. NO. 22 RK hg.a("a~13OC. NO. 19 SUPREME COUNTY COURT OF THE OF NEW YORK YORK OF NEW STATE -------------------------------------- x : JULIE : PARKER, : : - against HOWARD KEVIN 650126/2018 index No. Hon. Gerald : Plaintiff, - J.S.C. Lebovits : RUBIN, STIPULATION VOLUNTARY DISCONTINUANCE . : MAHANEY, I : Defendants. OF : : -: : : X IT HEREBY IS for Plaintiff counsel 1. Defendant Kevin 2. of 3. this No appointed Law hereby Mahaney of of C. William to this or conservatee an discontinues of her action and entries: Kevin Defendant Phillips with is an infant, no person Notice against claims A (Dkt. person incompetent a party Motion Nos. for has an interest No. Sequence Motion of Mahaney's Exhibit not Motion withdraws hereby docket following in Support party undersigned, as follows: Mahaney, voluntarily the (Dkt. to Dismiss 002, No. 15), (Dkt. No. 17 & 18). whom a committee in the subject has matter of action. 4. party This the Accordingly, with entirety each the Kevin between and by prejudice. Kevin the Affirmation 16), and with Mahaney, AOREED, Defendant Parker Julie specifically Memorandum and Parker, Defendant comprising been Julie Plaintiff AND STIPULATED prejudice to bear stipulation against as its own above-captioned costs may and be filed Defendant attorneys' without action shall be and is hereby Kevin Mahaney pursuant fees. The action continues further 1 of notice 2 18 of 319 2 of with the Clerk to discontinued CPLR against in its 3217(a), an other of the Court. with parties. F LF,-.: NEW YORK YORK COUNTY COUNTY CLERK FILED: NEW CLERK 04/06/2018 06:29 PM COUNTY YORK . sTc .. DOC. ncNSW NYSCEF NO. 22 N,Y6CL DOC. . NO. : 19 INDEX NO. INDEX NO. 650126/2018 650126/2018 65012 6/2018 NO. INDEX RECEIVED NYSCEF: 05/04/2018 RECEIVED NYSCEF: 05/04/2018 03/19/2018 NYSCEF: RECEIVED I Dated: New THE LAN New York, York 8,2018 March AU GROUP COVINGTON PC CL evin A. New (212) York, Ckdm Plaza, New York Suite 2000 Arlo 10111 Paul kevin@thelandaugroup.com Plaintiff Julie Parker Phillip Devlin-Brown Gillian 537-4025 Attorneyfor LLP . By: Landau 45 Rockefeller & BURLING A. Kassner F. Downs The New 620 Eighth New York, York Times Building Avenue New York 10018 (212) 841-1000 cphillips@cov.com adevlin-brown@cov.com gkassner@cov.com pdowns@cov.com Attorneys Mahaney 2 2 of,2 19 of 319 3 of Qf for Defendant Kevin