IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

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1 // :: PM CV JANE DOE, an individual, IN THE CIRCUIT COURT OF THE STATE OF OREGON Plaintiff, JOSEPH SCOTT HALL, an individual, v. Defendant. FOR THE COUNTY OF MULTNOMAH PlaintiffJane Doe (hereinafter referred to as "Plaintiff' hereby alleges as follows: Plaintiffwas, at all relevant times, a minor resident ofmultnomah County, Oregon. to as Defendant was a resident ofclackamas County, Oregon.. PARTIES l. Case No. COMPLAINT (Sexual Battery of a Child, False Imprisonment and Intentional Infliction ofemotional Distress Prayer Amount: $,0, Filing Fee: $.00 Per tors.0(1(d] Jury Trial Demanded At all times relevant to this Complaint, Defendant Joseph Scott Hall (hereinafter referred Page 1 - COMPLAINT SW Kelly Avenue, Ste. 0 Portland, Oregon Phone: (0-0 FacsImile: (0-0

2 1 1 FACTUAL BACKGROUND. At or around the end of January 1, Plaintiff went on-line on her i-pod to an application called "Local Chat: What's Good," a chat room designed to make connections to individuals close to the user's location. While also using the application, Defendant reached out to Plaintiff and they began to talk over the application. They talked daily for the next three weeks. Throughout this time, Plaintiffbelieved Defendant was a sixteen-year-old boy as listed on one of his Local Chat account profiles. Defendant was, in fact, thirty-nine ( years of age and did not have any profile pictures posted on any ofhis accounts.. On or about February, 1, Plaintiff sent Defendant a message letting him know that her parents were travelling to Eugene, Oregon that day and that she would be alone at home. She asked Defendant if he wanted to come over.. Defendant drove to Plaintiffs residence on February, 1, parking at the bottom of the hill from Plaintiffs home, walked up to the house and rang the doorbell. Plaintiff opened the door and was shocked to find Defendant was much older than a sixteen ( year-old boy.. Defendant forced his way into the house. He then forced Plaintiff to perform oral sex on Defendant and then proceeded to rape Plaintiff. After he had finished raping Plaintiff, Defendant left through the back sliding door ofthe house. FIRST CLAIM FOR RELIEF (Sexual Battery of a Child Plaintiffrealleges and incorporates herein paragraphs 1 through above. 1/1 1/1. Page - COMPLAINT SW Kelly Avenue, Ste. 0 Portland, Oregon Phone: (0-0 Facsimile: (0-0

3 1 1. Defendant deceived, induced, directed and forced Plaintiff to engage in various sexual acts with him. These acts constituted a harmful or offensive touching of Plaintiff to which she objected and could not consent due to her minority.. As a result and consequence ofdefendant's sexual battery, Plaintiff has suffered and will continue to suffer into the future severe and debilitating physical, mental, and emotional injury, all to her non-economic damage in the approximate amount of $ million.. As a result of Defendant's sexual abuse and molestation of Plaintiff, Plaintiff will continue to need psychological counseling for an indefinite length of time, to her economic damage in the amount of$0, SECOND CLAIM FOR RELIEF (False Imprisonment Plaintiffrealleges and incorporates herein paragraphs 1 through above.. 1. Defendant, a thirty-nine ( year-old adult, having met Plaintiff over the internet and deceived her into believing that he was a sixteen year-old boy, willfully and unlawfully detained Plaintiff at her house while her parents were away, without Plaintiff's consent, causing her false imprisonment. 1. As a result and consequence ofdefendant's false imprisonment, Plaintiffhas suffered and will continue to suffer into the future severe and debilitating physical, mental, and emotional injury, all to her non-economic damage in the approximate amount of $ million.. As a result of Defendant falsely imprisoning Plaintiff, Plaintiff will continue to need Page - COMPLAINT SW Kelly Avenue, Ste. 0 Portland, Oregon Phone: (0-0 Facsimile: (0-0

4 1 1 psychological counseling for an indefinite length oftime, to her economic damage in the amount of$1 00, THIRD CLAIM FOR RELIEF (Intentional Infliction of Severe Emotional Distress Plaintiffrealleges and incorporates herein paragraphs 1 through above... Defendant intended to inflict severe emotional distress on Plaintiff, and by his acts caused Plaintiffsevere emotional distress, acts that constituted an extraordinary transgression ofthe bounds ofsocially tolerable conduct.. As a result and consequence of Defendant's intentional infliction of severe emotional distress, Plaintiff has suffered and will continue to suffer into the future severe and debilitating physical, mental, and emotional injury, all to her non-economic damage in the approximate amount of $ million.. As a result of Defendant's intentional infliction of severe emotional distress on Plaintiff, Plaintiff will continue to need psychological counseling for an indefinite length of time, to her economic damage in the amount of$ioo,ooo.oo. PRAYER FOR RELIEF WHEREFORE, Plaintiff demands judgment against Defendant for Plaintiffs First, Second and Third Claims for Relief as follows: 1. Noneconomic damages in the amount of $ million;. Economic damages in the sum of$ioo,ooo.oo; /1/ /1/ Page - COMPLAINT SW Kelly Avenue, Ste. 0 Portland. Oregon Phone: (0-0 Facsimile: (0-0

5 . For Plaintiffs attorney fees, costs and disbursements incurred; and. For any other reliefthis court deems just and equitable. Dated this day ofjuly, Trial Attorney: Craig A. Nichols, OSB No Page - COMPLAINT SW Kelly Avenue, Sle. 0 Portland, Oregon Phone: (0-0 Facsimile: (0-0