Professional Documents
Culture Documents
Nygard Second Amended Complaint
Nygard Second Amended Complaint
Defendants.
This is a civil class action for damages under the United States Federal sex trafficking
statute, 18 U.S.C. §§ 1591, et seq. and other state and foreign laws, arising from Defendant Peter
J. Nygard’s (“Nygard”) rape, sexual assault, sexual battery, molestation, and/or sex trafficking of
Plaintiffs, Jane Does Nos. 1-57, and the other members of the Classes proposed below (the
“Class”), in the United States, the Commonwealth of the Bahamas, Canada, the United Kingdom,
and elsewhere around the world. Defendants (the corporate defendants are all referred to herein
as the “Nygard Companies”), using interstate and foreign commerce, conspired to and did recruit,
lure, and entice young, impressionable, and often impoverished children and women, with cash
payments and false promises of lucrative modeling opportunities or other career opportunities to
assault, rape, and sodomize them. Nygard used his considerable influence in the fashion industry,
his wealth, his power through corruption of officials, and a network of company employees under
his direction, to kidnap, groom and entice children and women. Defendants knew that Nygard
would use means of alcohol, drugs, force, fraud, and/or other forms of coercion to rape, sexually
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 2 of 270
assault, sexually batter, molest, and/or sex traffic these children and women and, in many cases,
with knowledge that they were younger than eighteen years old. Defendants knowingly benefited
from, and received value for, their participation in the conspiracy and/or venture and the Nygard
Companies knew, or should have known, that Nygard would rape, sexually assault, sexually batter,
molest, and/or sex traffic Jane Does Nos. 1-57 and the other Class members—many of whom were
with their global headquarters near Times Square in New York City, Nygard Holdings Limited
(“Nygard Holdings”), and Tan Jay International LTD (“Tan Jay”) (collectively, the “Nygard
Companies”), negligently supervised their employees and were also instrumental in knowingly
aiding, abetting, facilitating, and participating in Defendants’ decades-long sex trafficking scheme,
while knowing, or in reckless disregard of the fact, that Nygard would use means of force, fraud,
and/or coercion, or knowing that the person had not attained the age of eighteen years, to force
vulnerable children and women to engage in commercial sex acts in violation of the Trafficking
Victim Protection Reauthorization Act (“TVPRA”). The Nygard Companies also knowingly
conspired with Nygard to commit rape, sexual assault, molestation, and/or sexual battery in
violation of various state and foreign laws, including California, Florida, Canada, and the United
Kingdom. Nygard owned, directly or indirectly, all of these companies, controlled them,
commingled funds, disregarded all corporate formalities, and used them to commit his unlawful
acts.
aware of the investigation into their conspiracy and/or sex trafficking venture, through Nygard and
other upper-level employees, they resorted to tactics of violence, intimidation, bribery, payoffs,
2
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 3 of 270
and evidence destruction to attempt to silence the victims and to continue their conspiracy and/or
scheme.
INTRODUCTION
1. The Nygard Companies, through Nygard and a close ring of upper-level executives,
directors, officers, and employees, negligently supervised company personnel and employees and
knowingly and continuously conspired with Nygard to enable, act as a front, and conceal Nygard’s
criminal activity.
spanning at least five decades—between Nygard, upper-level employees, officers, and directors,
of the Nygard Companies, and other individuals, including, without limitation, Vice Chairman,
Jim Bennett, Executive Vice President, Rick Wanzel, Executive Vice President and General
Manager, David Paton, Director of Systems, Greg Fenske, Princy Mathew, Kevin Carkner,
Marketing and Promotions Director, Tiina Tulikorpi, CEO, Sajjad Hudda, President and CEO,
Denis LaPointe, Director of Human Resources, Wajma Popal, corporate accountant, Lili Micic,
and Property and/or General Managers of Marina Del Rey, Angela and Marten Dyborn, and the
Nygard Companies (for this Amended Complaint, “Nygard Companies” includes predecessor
entities and affiliates such as Tan Jay), resulting in a pattern and practice of rape, sexual assault,
sexual battery, molestation, and sex trafficking in countries across the globe, including the United
States, Canada, the Bahamas, the United Kingdom, and other countries.
3. These upper-level executives, officers, and directors knew or should have known,
through the exercise of reasonable diligence, of Nygard’s continuing conspiracy and/or sex
trafficking venture; and were grossly negligent and violated their fiduciary duties to the Nygard
Companies and the public by enabling and/or participating in Nygard’s misconduct and permitting
3
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 4 of 270
him to use the money and resources of the Nygard Companies to further his conspiracy and/or sex
trafficking venture.
4. Nygard uses the Nygard Companies’ resources and brand to rape, sexually assault,
sexually batter, molest, sex traffic, wrongfully detain, cause bodily injury, and invade the privacy
of children and women. In turn, the Nygard Companies, through their executives, officers,
directors, and employees, have participated in and covered-up his crimes for decades so that they
can continue to benefit financially and professionally from Nygard’s name, brand, and money.
5. Over the past decades, at least nine women in Canada and California have sued
Nygard or reported him to the authorities, alleging sexual misconduct.1 Another nine former
employees said in interviews that he had raped them, touched them in appropriately, or proposed
sex.2 In many instances, the Nygard Companies arranged to payoff these victims and forced them
6. Scores of other victims have yet to come forward to report his crimes. Until
recently, Nygard has largely been able to silence his victims, with the help of the Nygard
Companies and their upper-level executives and employees, through various tactics including
Nygard “has been accused of abusive labor practices, tax evasion, sexual harassment and rape.”3
1
https://www.nytimes.com/2020/02/22/world/americas/peter-nygard-louis-
bacon.html?referringSource=articleShare
2
https://www.nytimes.com/2020/02/25/us/peter-nygard-international-fbi-raid.html
3
https://www.forbes.com/forbes/2010/1206/features-peter-nygard-sexual-harassment-answers-to-no-
one.html#236f0e30bc9b
4
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 5 of 270
8. Nygard is the founder, chairman, figurehead, chief executive, and icon of the
Nygard Companies.4
9. Directly or indirectly, Nygard owned 100% of the Nygard Companies at the time
10. Although Nygard has publicly stepped down from the Nygard Companies, he has
not divested his ownership interest in the Nygard Companies, and he continues to run and direct
the Nygard Companies from behind the scenes. A Canadian judge, in connection with the Nygard
Companies’ bankruptcy proceedings, has recently found that “[t]here is no evidence that Mr.
Nygard has indeed resigned, and 100 percent of the shares of the Nygard Group” are still owned
by him. Another source has confirmed that he is still running the Nygard Companies from his
Winnipeg home.
11. Nygard entirely controls each of the Nygard Companies. He calls all the shots and
is accountable to no one. His Board consists of himself and two division presidents.5
12. At Nygard’s direction, the Nygard Companies commingle funds and do not observe
corporate formalities.
13. Nygard is the Nygard Companies; the Nygard Companies are Nygard.
14. Indeed, Nygard proclaims in public filings that he and his businesses are “closely
4
Unless otherwise specified, all of the allegations in Plaintiffs’ First Amended Complaint pertain to the
time period in which the acts detailed in the Complaint occurred.
5
- https://www.forbes.com/forbes/2010/1206/features-peter-nygard-sexual-harassment-answers-to-no-
one.html#236f0e30bc9b
6
Complaint at ¶ 31, Nygard, et al. v. Dipaolo, et al., No. 17-cv-60027 (S.D.N.Y. Jan. 5, 2017), at ¶¶ 1,
31.
5
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 6 of 270
15. The Nygard Companies’ promotional materials and advertisements also make the
companies synonymous with “one man,” Nygard, who is featured individually on almost all
16. Nygard and his businesses are “closely identified in the public mind, similar to
17. Nygard Inc. and Nygard International have their global headquarters near Times
18. Nygard and his companies have repeatedly invoked the jurisdiction of the United
States courts by filing lawsuits in multiple United States courts, including this District.9
19. Nygard has a residence in New York City, which is above his flagship store near
20. Further, Jane Does Nos. 12, 13, 39, 41, 46, 51, and 57 were raped, sexually
assaulted, sexually battered, molested, sex trafficked, wrongfully detained, physically injured,
21. Nygard also resides in Marina Del Rey, California where, as detailed throughout
this First Amended Complaint, Nygard also raped, sexually assaulted, sexually battered, molested,
sex trafficked, wrongfully detained, physically injured, and/or invaded the privacy of his victims,
7
See, e.g., video at https://corporate.nygard.com/.
8
See Complaint at ¶ 31, Nygard, et al. v. Dipaolo, et al., No. 17-cv-60027 (S.D. Fla. Jan. 5, 2017).
9
See, e.g., Nygard, et al. v. Bacon, No. 1:19-cv-01559-LGS-KNF (S.D.N.Y. Feb. 19, 2019); Nygard, et al.
v. Dipaolo, et al., No. 17-cv-60027, 2017 WL 4303825 (S.D. Fla. Jan. 5, 2017); Nygard International
Partnership v. Feralio, No. B266683, 2017 WL 4784925 (Cal. Ct. App. Oct. 24, 2017); Nygard v. Jasper,
No. 8:15-cv-1939-T-33EAJ, 2016 WL 9526666 (M.D. Fla. Jan. 4, 2016); Nygard, Inc. v. Uusi-Kerttula,
159 Cal.App.4th 1027 (Cal. Ct. App. 2008); Nygard, Inc. v. Kustannusosakeyhtio Iltalehti, No. B192639,
2007 WL 1775963 (Cal. Ct. App. June 21, 2007).
6
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 7 of 270
including Jane Does Nos. 9, 17, 21, 24, 25, 29, 20, 28, 43, 45, 47, 52, and 55 and other members
of the Class.
22. Nygard owns the companies Nygard NY Retail, LLC, Nygard Partners, LLC, and
23. At the heart of this action is a continuing conspiracy between Nygard, upper-level
employees, officers, and directors of the Nygard Companies including, without limitation, Vice
Chairman, Jim Bennett, Executive Vice President, Rick Wanzel, Executive Vice President and
General Manager, David Paton, Director of Systems, Greg Fenske, Princy Mathew, Kevin
Carkner, Marketing and Promotions Director, Tiina Tulikorpi, CEO, Sajjad Hudda, President and
CEO, Denis LaPointe, Director of Human Resources, Wajma Popal, corporate accountant, Lili
Micic, and Property and/or General Managers of Marina Del Rey, Angela and Marten Dyborn,
and the Nygard Companies to use the Nygard Companies to facilitate and enable the rape, sexual
assault, sexual battery, molestation, and sex trafficking of children and women in the United States,
the Bahamas, Canada, the United Kingdom, and elsewhere around the world.
24. The Nygard Companies fund Nygard’s illegal sex trafficking conspiracy and
venture, and Nygard uses the Nygard Companies’ brand, resources, and promotional events to
facilitate the rape, sexual assault, molestation, and sexual battery of his victims and to recruit, lure,
and/or entice his victims and force, defraud, or coerce them, or knowing that the victim has not
attained the age of eighteen years, into engaging in commercial sex acts.
25. In turn, the Nygard Companies and their employees knowingly benefit from their
participation in and cover-up of Nygard’s conspiracy and/or sex trafficking venture by the
continued promotion of the Nygard brand, the propagation of his playboy image, and by using
7
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 8 of 270
26. Nygard, conspiring with the employees, officers, and directors referenced above,
and the Nygard Companies, use their resources and brand, engaged in a pattern and practice of
rape, sexual assault, molestation, and sexual battery, including recruiting, luring, enticing, and
obtaining children and women, and causing them through force, fraud or coercion, or knowing that
the victim had not yet attained the age of eighteen years, to engage in commercial sex acts through,
among other means, promising lucrative modeling opportunities and other career opportunities,
providing cash payments, drugging his victims, confiscating his victims’ passports, preventing his
victims from exiting the Nygard Cay property in the Bahamas and properties in the United States
and Canada, threatening victims with physical violence, and using physical force against them.
27. Nygard recruited, lured, and enticed some of his victims, as alleged herein, to
engage in commercial sex acts in, among other places, New York, California, and Florida. Jane
Does Nos. 12, 13, 39, 41, 46, 51, and 57 were raped, sexually assaulted, sexually battered,
molested, and/or sex trafficked in New York. Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45,
47, 52, and 55 were raped, sexually assaulted, sexually battered, molested, and/or sex trafficked in
California. Jane Doe No. 41 was raped, sexually assaulted, and/or sex trafficked in Florida.
28. The Nygard Companies have actual knowledge of Nygard’s unlawful commercial
sex acts and sexual assaults through him, as he is (and was during the relevant time periods herein)
the founder, chairman, and 100% owner of the Nygard Companies. Other high-ranking executives
and employees of the Nygard Companies also have direct knowledge of and have covered-up
Nygard’s criminal activity including, without limitation, the executives and employees identified
above.
29. One day after the Complaint in this matter was filed, high-ranking executives of the
Nygard Companies approached members of the corporate IT department and instructed them, at
8
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 9 of 270
Nygard’s direction, to “clean up” the corporate website10 and remove public access to corporate
social media accounts,11 including corporate webpages and videos promoting “pamper parties”
30. It was not until almost two weeks after the Complaint was filed, and after the FBI
served a subpoena on the Nygard entities, that the Nygard Companies finally issued an internal
31. Even after the internal memo was issued, employees of the Nygard Companies were
instructed by executives of the Nygard Companies to delete thousands of electronic files from the
corporate computer systems. Richter Advisory Group, Inc. (“Richter”) authored a report
concluding that 10,488 electronic files were deleted after the internal memo was issued.
32. The majority of the file deletions were concentrated among three users. Two of the
users were corporate IT accounts that would have known that files were not supposed to be deleted,
pursuant to the internal memo. The third user was Greg Fenske (“Fenske”), a co-conspirator who
has knowingly enabled and facilitated Nygard’s crimes. Fenske deleted a total of 1,059 files on
March 18, 2020—the exact date that Richter was appointed bankruptcy receiver and Defendants
lost autonomy over their computer systems. In the three weeks prior to Richter’s appointment,
Fenske had very little deletion activity, showing that his conduct was not routine.
10
The Nygard Companies’ Corporate website, including pages explicitly cited in Plaintiffs’ Complaint, is
no longer accessible by the public. See, e.g., https://corporate.nygard.com/about-nygard/
11
The Nygard Companies have removed public access to social media accounts, including videos
explicitly cited in Plaintiffs’ Complaint, that promote “pamper parties” and Nygard’s playboy image.
See,e.g., https://www.youtube.com/watch?v=WPFz3_yfj2I.
12
Ryan Thorpe, Internal memo tells Nygard employees to preserve documents, Winnipeg Free Press
(March 11, 2020), available at https://www.winnipegfreepress.com/local/internal-memo-tells-nygard-
employees-to-preserve-documents-568713862.html
9
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 10 of 270
33. Further, the Nygard Companies, through Nygard and their officers and directors,
negligently supervised their employees, knowingly conspired, aided and abetted, facilitated, and
participated in Nygard’s illegal sex trafficking venture and/or conspiracy by being integrally
involved in the sex trafficking, assault, and rape of children and young women, examples of which
a. Defendants used the Nygard Companies’ money, brand, and resources to facilitate
and commit rapes, sexual assaults, sexual batteries, molestations, and commercial
sex acts in the United States, Bahamas, Canada, the United Kingdom, and
b. Defendants used the guise of modeling or other career opportunities with the
Nygard Companies to recruit, lure and entice young girls and women to locations
in New York, California, Winnipeg, Toronto, Montreal, and the Bahamas so that
Nygard could rape, sexually assault, sexually batter, molest, and sex traffic them.
Bahamas and California under the Nygard brand and with the Nygard Companies’
resources, to both promote the Nygard Companies’ brand and facilitate rape, sexual
assault, sexual battery, molestation, and commercial sex acts. In doing so, Nygard
was acting on behalf of the Nygard Companies, under the brand and reputation of
the Nygard Companies, and using the Nygard Companies to commit and cover-up
his crimes.
d. Defendants used fraud and deceit to knowingly lure and entice children and women
to his Nygard Cay and Marina Del Rey properties under the false pretense of
13
See https://www.youtube.com/watch?v=WPFz3_yfj2I
10
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 11 of 270
attending “pamper parties” and promising, among other things, interviews for
e. The Nygard Companies funded Nygard’s “pamper parties” in California under the
Nygard brand by using cash from the bank accounts of the Companies,
headquartered in New York, routing the wires through New York, and using the
money and resources to fund Defendants’ conspiracy and/or sex trafficking venture
by purchasing supplies for “pamper parties,” paying employees and staff to work
the “pamper parties” and recruit new victims at the “pamper parties,” and directly
f. The Nygard Companies funded Nygard’s “pamper parties” in the Bahamas under
the Nygard brand by transferring cash from their bank account in Canada, routing
it through New York, and depositing it in a Bahamian bank account that belongs to
g. The Nygard Companies used corporate accounts to pay for drugs, alcohol,
entertainment, services, and food for the “pamper parties,” and also provided the
cash that Nygard delivered to accomplices and victims to facilitate Nygard’s rape,
sexual assault, sexual battery, molestation, and/or sex trafficking of children and
young women.
h. The Nygard Companies also paid all employees and staff, including accomplices
who recruited and groomed children and women to engage in commercial sex acts,
11
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 12 of 270
i. The Nygard Companies paid, promoted, and/or advanced the careers of executives
and employees so that they would “recruit” victims, turn a blind-eye to Nygard’s
j. Nygard used the Nygard Companies’ boats, including but not limited to, the “Yves
Lauren,” “Heesen MIRAGE,” and “Lady Hilkka,” at least one of which is docked
in Florida, for months at a time, to transport drugs, liquor, and supplies for the
“pamper parties.”
k. Nygard used the Nygard Companies’ employees, resources, and the Nygard
United States, Canada, the Bahamas, and around the world including, without
limitation, his residences and locations in the Bahamas, California, Florida, New
l. Nygard also used the Nygard Companies’ resources including, without limitation,
the corporate jet, to smuggle women, drugs, liquor, and other supplies into and out
m. The victims that Nygard found most attractive and sexually desirable were forced
and physical force, or knowing that the victim had not attained the age of eighteen
n. Nygard’s “girlfriends” were coerced and enticed to move into his Nygard Cay,
Marina Del Rey, and/or other properties with promises of money and/or future
modeling or career opportunities, where they were not allowed to leave without his
12
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 13 of 270
express permission. They were forced to meet his every demand including, without
limitation, “recruiting” new victims to attend his “pamper parties” and other events
so that Defendants could continue their conspiracy and Nygard could continue his
sponsored fashion tours in the United States, Canada, and elsewhere around the
world, where they were required to commit commercial sex acts that satisfied his
perverse sexual desires, “recruit” new victims for him while on tour, and provide
p. Nygard’s “girlfriends” were always paid varying amounts of cash in United States
personnel, and paid directly by Nygard to help ensure their compliance and silence.
Nygard’s longtime “girlfriends” were also put on the Nygard Companies’ official
payroll. They were paid monthly through direct deposit with funds from a Nygard
corporate account by the Nygard corporate accountant, often Lili Micic. They were
required to submit invoices that stated that they were being paid for “modeling and
payments were based upon their level of servitude to Nygard, their ability to satisfy
his sexual desires, and their ability to “recruit” new victims for him to rape, sexually
assault, sexually batter, molest, and engage in commercial sex acts with.
13
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 14 of 270
q. Travel arrangements for Nygard’s “girlfriends” and victims were made and paid
United States.
r. Nygard frequently took his “girlfriends” and victims to his New York City
clubs in New York City. While at the “swingers” clubs, Nygard forced his
“girlfriends” to find couples for him to have sex with. He then paid, forced, and/or
coerced his “girlfriends” to have sex with other men, while he watched and engaged
in sex with the men’s partners. Nygard treated sex like a currency.
computers, email, phones, and social-media accounts to lure his victims to locations
in the United States, the Bahamas, Canada, and elsewhere around the world, so that
Nygard could rape, sexually assault, sexually batter, molest, or use force, fraud and
coercion, or knowing the victim had not attained the age of eighteen years, to cause
t. Nygard kept a database of potential victims that was maintained by the Nygard
server (mostly maintained in the United States). By the mid-2000s, this database
was confirmed to have contained information on over 7,500 underage girls and
women.
u. The Nygard Companies and Nygard employed people to work at what Nygard
Among other duties, ComCor employees were used to ensure that Nygard’s
14
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 15 of 270
potential victims attended the “pamper parties” by contacting them and arranging
for their transportation to the parties. Thereafter, Nygard seduced, coerced, incited,
paid, and promised these victims modeling and other career opportunities to rape,
sex acts. All ComCor employees were paid by the Nygard Companies.
v. Upon arrival at the gated Nygard Cay and Marina Del Rey properties, Nygard
required his employees to “register” his victims with ComCor, which was in charge
information, such as their names, telephone numbers, email addresses, and the
identities of the persons who invited them. They were also required to pose for
headshots and full-body photographs. The pictures and registration forms, filled
out by the Nygard Companies’ employees, were scanned and emailed directly to
Nygard, so that he could review who was in attendance and rate or grade his
potential victims, while sitting upstairs in his bedroom. Nygard would then use this
information to select his potential victims, based upon the ratings he gave pursuant
to his self-avowed standard of: “an eight in the face, and a nice toilet.”
w. The information was then entered into a Company database by ComCor employees,
at Nygard’s direction, so that Nygard had a ready list of “prospective recruits” who
were potential victims to pursue at any given time. The database contains ratings
or grades, information, and pictures of over 7,500 underage girls and women dating
back to 1987. The database was hosted on a corporate server and was maintained
15
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 16 of 270
was responsible for reviewing every single email sent to Nygard and had perhaps
the most knowledge of any person other than Peter Nygard. At the young age of
44, with no known serious health issues, Mr. Clifford died suddenly just a few
months ago (just a few weeks after The New York Times was known to be
investigating this story and had contacted Mr. Clifford). The family characterized
x. Nygard’s ComCor was used to keep track of, make contact with, and lure potential
victims to New York, Nygard Cay, Marina Del Rey, and other properties in Canada
and the United States through the database. Nygard instructed the Company-paid
employees to call and text potential victims to invite them to “pamper parties,”
transport girls to and from the “pamper parties,” or to otherwise pay for their
transportation.
y. Nygard’s ComCor also used social media to post about “pamper parties” and to
“pamper parties.” Nygard’s ComCor knowingly recruited these victims for Nygard
and were paid by the Nygard Companies, headquartered in New York, with cash
routed through New York and paid out of the Nygard Companies’ corporate
accounts.
14
See https://www.linkedin.com/in/daane-clifford-9a180332/?originalSubdomain=ca; see also
https://www.dignitymemorial.com/obituaries/langley-bc/daane-clifford-8735816.
16
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 17 of 270
Nygard, on his own and through his direction to his employees, paid many of his
aa. Nygard used his financial resources, influence, power in the Bahamas, Canada, and
prevent his crimes from being reported. Those of his “girlfriends” who tried to
leave him were harassed and threatened by Bahamian police who were on Nygard’s
payroll (and who were paid with Nygard Companies’ United States currency).
bb. Nygard and the Nygard Companies made a concentrated and deliberate effort to
protect and conceal Nygard’s criminal activities. For example, Nygard initiated a
scheme to purchase police protection and political cover in the Bahamas, using
former Cabinet Minister who became the Prime Minister of the Bahamas. This
scheme was so powerful and successful that victims who escaped Nygard Cay were
cc. After a kidnapping and multi-day rape of a Canadian victim, Nygard’s nephew
picked up the victim from a warehouse and instructed the victim not to call the
dd. Nygard and the Nygard Companies, with knowledge of his criminal activity, also
17
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 18 of 270
them from reporting his illegal activity. Nygard and the Nygard Companies also
threaten to sue or sue anyone who goes public with accusations against him.15
ee. Nygard and the Nygard Companies, with knowledge of his criminal activity, have
also paid-off numerous victims and forced them to sign non-disclosure agreements
ff. Longtime employee of the Nygard Companies, Angela Dyborn, has also conspired
gg. Nygard used funds from the Nygard Companies to make political contributions and
bribe and/or payoff government officials and law enforcement personnel to further
Defendants’ conspiracy and/or sex trafficking venture and cover-up his crimes.
hh. In an effort to reinforce fear, control, and dominance over his victims, Nygard
regularly flaunted his political power to control the Bahamian police and the
ii. Nygard also paid people, using Nygard Company money, to intimidate his former
34. Nygard intentionally used the Nygard Companies’ resources and brand to rape,
sexually assault, sexually batter, molest, and/or recruit, lure, and entice children and women to
15
See, e.g., Nygard, Inc. v. Uusi-Kerttula, 159 Cal. App. 4th 1027 (2008); Nygard, Inc. v.
Kustannusosakeyhtio Iltalehti, No. B192639, 2007 WL 1775963 (Cal. Ct. App. June 21, 2007);
https://www.theglobeandmail.com/news/national/fashion-tycoon-peter-nygard-files-criminal-complaint-
against-cbc/article574862/
18
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 19 of 270
cause them to engage in commercial sex acts and other degrading acts, for which he always
35. Further, the Nygard Companies knowingly financed Nygard’s commercial sex acts
as well as facilitated and enabled the rape, sexual assault, molestation, and sexual battery of his
victims.
36. The Nygard Companies marketed Nygard’s playboy image, the Nygard Cay16 and
Marina Del Rey17 properties, and “pamper parties” as part of the Nygard brand, which benefited
the Nygard Companies18 and provided Nygard with access to a steady supply of victims. Nygard’s
public image was used to promote the Nygard brand and its products in the Bahamas and around
the world, as well as to facilitate Defendants’ conspiracy and/or sex trafficking venture.
37. The Nygard Companies promoted and/or furthered the careers of employees who
facilitated, aided and abetted, and covered-up Nygard’s sex crimes so they could benefit from
38. The Nygard Companies knowingly benefited financially from Nygard’s conspiracy
and/or sex-trafficking venture. By facilitating and covering-up Nygard’s rapes, sexual assaults,
sexual batteries, molestations, and commercial sex acts in foreign commerce, the Nygard
Companies enjoyed the promotion and promulgation of the Nygard Companies’ projects
16
See, e.g.
http://pimpingpictures.com/Jarmopohjaniemi.com/Blog/Entries/2008/6/11_Nygard_Cay_Hosts_Playboy_
Shoot.html; http://travelingstarproductions.com/OO/RaceyGirl.htm;
https://web.archive.org/web/20130730175349/http://corporate.nygard.com/SCF/NygardCayBahamas.asp
x?ID=38&Folder_id=55
17
See, e.g. https://www.instagram.com/p/BehBmpwDZW-/?hl=en
18
https://www.youtube.com/watch?v=9sb2TEoqZtw; https://www.youtube.com/watch?v=WPFz3_yfj2I;
https://www.youtube.com/watch?v=nIJWrU9wq7w
19
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 20 of 270
internationally. Nygard is the face of the Nygard Companies, and his presence and promotion in
39. The Nygard Companies facilitated Nygard’s rapes, sexual assaults, sexual batteries,
molestations, and commercial sex acts in foreign commerce to obtain the enormous publicity that
Nygard garnered by promoting the Nygard Companies’ products internationally, as well as acting
as a pimp between high powered individuals who, in return, gave favorable dealings to the Nygard
40. The Nygard Companies also benefited from the services that Nygard’s sex workers
were forced to provide to the Nygard Companies including, without limitation, modeling company
clothing for company executives, their clothing design ideas, preparing Nygard for his business
meetings, attending business meetings, and perpetuating Nygard’s playboy image, which is a
crucial component of the Nygard brand. Indeed, the Nygard Companies’ corporate website touts
Nygard’s “reputation of a playboy entrepreneur” who “knows what women want,” a marketing
plan that is “by design” and makes women “love to wear his fashions.”19
41. This Paragraph’s table synthesizes the horrific facts (presented in greater detail later
on in this Amended Complaint) of Nygard’s rape and sexual assault of Jane Does Nos. 1-57,
effectuated and facilitated through the Nygard Companies’ resources, assets, and employees. The
table details Nygard’s penchant for vicious, unimaginable rape of children and women.
19
http://www4.nygard.com/scf/News.aspx?id=7774
20
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 21 of 270
Over her objections, Nygard used force ComCor workers called her
and fear to have her penetrate his anus to invite her to a “pamper
with a lubricated dildo, while he party.”
masturbated.
After being raped at the
Nygard approached her and she asked “pamper party,” she went
him to stop. Nygard, ignoring her back to the dining area,
rejection, reached around her neck, where she found the two
began unzipping her dress, put on a Nygard employees who
condom, kissed her, and began to open brought her there. A
her legs. As she tried to close her legs Nygard employee escorted
and push him off of her, he held her her to a car and transported
hands back and pinned them against her back home.
the headboard.
The Nygard Companies
The victim, a virgin, cried as Nygard supplied the cash paid to the
forced his penis into her vagina, victim.
causing extraordinary trauma and pain.
14 2 Over her objections, Nygard served her Upon reaching Nygard Cay
several glasses of wine. Nygard’s for a “pamper party,”
employees brought him a bag of pills. ComCor employees took
Nygard gave her three pills and down her contact
instructed her to take them all at once information and
with her wine. photographed her.
21
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 22 of 270
Nygard gave her approximately $5,000 if she was okay and if she
in $100 bills in U.S. currency. She would ever return to Nygard
initially refused to take the money, but Cay. Jane Doe No. 2
Nygard insisted. responded that she would
think about it. Nygard’s
She was a virgin prior to being raped assistant explained that
by Nygard. Nygard was not really a bad
person but was just selfish at
On another visit to a “pamper party,” times.
Nygard had her play with his genitals
and had her penetrate his anus with a On a separate occasion, a
lubricated dildo. ComCor employee texted
her to come to another
After this second instance of rape, “pamper party.”
Nygard began paying her to be a
Nygard model and to recruit other After her other visit to
young girls for him to sleep with, so Nygard Cay, during which
that she would not have to satisfy his she was forced to play with
perverse sexual desires herself. Nygard’s genitals and
Nygard would instruct her to offer the penetrate his anus with a
young girls drugs. Each time that she dildo, she received
visited Nygard Cay and recruited girls numerous text messages
for him, Nygard gave her a large sum from a Nygard ComCor
of cash—never less than $2,000 and employee inviting her to
always in U.S. currency. travel with Nygard to Ohio,
Canada, and New York.
At another visit to Nygard Cay for a
“pamper party,” Nygard insisted that The Nygard Companies
she defecate and/or urinate in his supplied the cash paid to the
mouth. She responded that she did not victim.
wish to do that to him. He offered to
give her drugs that would help her
defecate. She told Nygard no and
decided that she could no longer take
Nygard’s perverse sexual fetishes.
22
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 23 of 270
Nygard asked her if she had sex before; Jane Doe No. 3 to Nygard’s
she said no. At this point, she became bedroom, where he was
afraid. waiting.
Nygard sat her on the bed and began to After Nygard raped Jane
rub her legs and face. He sat down Doe No. 3 in his bedroom,
next to her and slowly pushed her body the ComCor employee
back onto the bed. Nygard took a returned to the bedroom to
condom from the drawer and put it on. pick up Jane Doe No. 3. The
He began kissing her on her stomach; ComCor employee asked
she began trembling in fear. Jane Doe No. 3 if she was
okay. Jane Doe No. 3
She shouted “no” and began to cry. responded that she was
Nygard grabbed her closer, put all of afraid.
his weight on her, and penetrated her
vagina with his penis. She told him to Before Jane Doe No. 3 left
stop and resisted him, but he continued. the ComCor employee, on
behalf of Nygard, handed
After Nygard ceased vaginally raping Jane Doe No. 3
her, she was bleeding from her vagina. approximately $200 in U.S.
There was also blood on the sheets. currency.
14 4 Jane Doe No. 4 is the younger cousin She was registered at the
of Jane Doe No. 3 (referenced in the security station at the
row above). Nygard Cay gate when
attending a “pamper party.”
At the “pamper party,” she was given
an alcoholic drink. A ComCor employee was
with Jane Doe No. 4 at the
Nygard escorted her to his bedroom. “pamper party.”
Once they arrived in the bedroom,
Nygard invited her to get comfortable
on the bed. Nygard turned on the
23
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 24 of 270
17 5 Jane Doe No. 5’s friend, invited her to Jane Doe No. 5 and her
a “pamper party.” While at the party, friend were transported to
Jane Doe No. 5 consumed multiple and from Nygard Cay by a
alcoholic beverages. Nygard Company employee.
24
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 25 of 270
While they were drinking on the beach, Upon arriving, they were
Nygard approached her friend and registered by the Nygard
gestured at her to follow him. Her Companies’ ComCor
friend motioned to Jane Doe No. 5 to employees.
come with her because she did not The Nygard Companies
want to go with Nygard alone. supplied the cash paid to the
victim.
Nygard took them up to his bedroom
and gave them more to drink. Jane
Doe No. 5 began to feel very “loose.”
Nygard instructed the girls to touch one
another sexually, and they complied.
After several minutes, Nygard joined
and began touching the girls.
During the encounter, Nygard
sodomized Jane Doe No. 5 against her
will. Afterwards, she was bleeding
from her anus.
15 6 Jane Doe No. 6 was invited to Nygard Jane Doe No. 6 was invited
Cay by the Nygard Cay DJ, named to a “pamper party” at
“Shorts.” Nygard Cay by the Nygard
While at the “pamper party,” an Cay DJ, “Shorts.”
acquaintance introduced her to Nygard
and told her Nygard could get her some The Nygard Companies
marijuana to smoke. Nygard invited supplied the cash that
her upstairs to smoke marijuana. Nygard attempted to pay the
victim.
Nygard took her to his bedroom. He
undressed and got into the Jacuzzi.
After Jane Doe No. 6 declined to get in
with him, he got out of the Jacuzzi and
began to undress her.
25
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 26 of 270
26
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 27 of 270
29 8 Jane Doe No. 8 was a key employee of Jane Doe No. 8 was
Nygard Cay for several years, employed and paid by the
providing services for guests and for Nygard Companies. Jane
Nygard from 2008-2014. Doe No. 8’s continued
employment with the
In 2014, Jane Doe No. 8 was raped. Nygard Companies was
She rarely drinks while at work; conditioned upon sex with
however, she accepted a glass of wine Nygard.
from one of Nygard’s girlfriends
shortly before being summoned to Resources of the Nygard
Nygard’s room. Shortly after arriving, Companies were used to
she noticed her arms become numb and abduct Jane Doe No. 8.
then she fell unconscious. When she
became awake again, Nygard was in
the act of penetrating her vagina with
his penis.
Adult 9 Jane Doe No. 9 was an employee of Jane Doe No. 9 was an
Nygard and the Nygard Companies. employee of the Nygard
Over the years she was sexually Companies. Nygard used
assaulted by Nygard on numerous her continued employment
occasions. and payment as a means to
control and to coerce her
In 2015, she was raped by Nygard at into sex acts.
his residence in Marina Del Ray,
California. He overrode the lock on
her guest room bedroom and entered
without her permission. She awoke to
him forcefully and physically
attempting to rape her. Despite her
27
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 28 of 270
28
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 29 of 270
urinate and defecate on him. After Jane Doe No. 11 was first
Nygard fell asleep, Jane Doe No.11 “recruited” to attend a
snuck out of bed and jumped the gate “pamper party” by an
to escape from Nygard Cay. employee of the Nygard
Companies. She was
She was a virgin prior to being raped registered at the gate by
by Nygard. ComCor.
A month or two later, Jane Doe No. 11 Nygard promised Jane Doe
began regularly attending “pamper No. 11 a job with the
parties” after being contacted by the Nygard Companies in return
Nygard Companies’ ComCor and for commercial sex acts and
having Nygard’s contacts threaten and “recruiting” for Nygard.
coerce not to tell anyone about the
sexual acts that had occurred. Jane Nygard employees
Doe No. 11 was promised a job threatened and coerced Jane
working for the Nygard Companies if Doe No. 11 not to tell
she would “recruit” for Nygard. anyone about the sexual acts
that had occurred between
On at least one occasion after the first her and Nygard.
rape, Jane Doe. No. 11 was drugged
before being raped by Nygard again.
25 12 Jane Doe No. 12 first attended a Jane Doe No. 12 was first
“pamper party” at Nygard Cay when “recruited” to attend a
she was twenty-five years old. “pamper party” by a Nygard
Companies’ ComCor
She was later lured, enticed, coerced employee. She was
and recruited to become a “girlfriend” registered at the gate by
of Nygard, which lasted for ComCor.
approximately six years.
The Nygard Companies paid
Jane Doe No. 12 was paid a monthly for the supplies, food, and
salary by the Nygard Companies to be alcohol at the “pamper
Nygard’s full-time sex worker. Jane party.”
Doe No. 12 was expected to be at
Nygard’s beck and call for commercial The Nygard Companies paid
sex acts and “recruitment” of other Jane Doe No. 12 via direct
girls and women twenty-four hours per deposit for commercial sex
day, seven days per week whenever acts with Nygard and others
she was with Nygard. at Nygard’s direction and
for the benefit of Nygard
Jane Doe No. 12 was also coerced to and Nygard Companies.
“recruit” new victims for Nygard. Jane Doe No. 12 traveled
Nygard instructed Jane Doe No. 12 to with Nygard on the Nygard
Companies’ corporate jet to
29
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 30 of 270
17 13 Jane Doe No. 13 travelled to New York Jane Doe No. 13 was
City at the age of seventeen to meet provided alcohol and drugs
with a Nygard recruiter who was also a by Nygard employees and
“talent agent,” currently based in Los paid for by the Nygard
Angeles and prominently markets Companies.
himself to the celebrity world. The
talent agent took photos of Jane Doe The Nygard Companies
No. 13 and sent them to Nygard, who were used as the false lure
then “approved” Jane Doe No. 13 for of a modeling opportunity to
modeling with the Nygard Companies. bring the victim to Nygard.
The “talent agent” took the minor child Jane Doe No. 13 was taken
to Nygard’s New York City apartment to Nygard’s apartment
to meet Nygard under the guise of a which was paid for by the
Nygard Companies and
30
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 31 of 270
24 14 Jane Doe No. 14 met with Nygard Jane Doe No. 14 was
under the guise of interviewing for an “recruited” for Nygard by
office job with the Nygard Companies an employee of the Nygard
in the Toronto office. While she waited Companies.
for Nygard and the interview to begin,
she was served a drugged beverage by Jane Doe No. 14 applied for
an employee of the Nygard Companies an advertised job
and/or paid “girlfriend.” opportunity with the Nygard
When Nygard arrived, Jane Doe No. 14 Companies.
was brought to a bedroom where she
was raped on the bed. At some point An employee of the Nygard
during the rape, she became Companies and/or paid
unconscious. “girlfriend” drugged Jane
Doe No. 14 with drugs
Jane Doe No. 14 woke up in a purchased by the Nygard
basement on a mat with Nygard’s Companies.
employee and two other women.
Nygard’s employee told her she got the Jane Doe No. 14 was raped
job and let her out. Jane Doe No. 14 and held captive at an office
agreed not tell anyone what happened. building of the Nygard
Companies.
Jane Doe No. 14 was flown to New
York City on the Nygard Companies’ Jane Doe No. 14 was flown
corporate jet under the guise of to New York City on the
beginning her new position; in reality, Nygard Companies’
it was for the purpose of raping and/or corporate jet under the guise
trafficking her. She was able to avoid of a job interview with the
a second victimization. Nygard Companies.
20 15 Jane Doe No. 15 was flown to the Jane Doe No. 15 was flown
Nygard Companies’ Winnipeg to the Nygard Companies’
31
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 32 of 270
19 16 Jane Doe No. 16 was “recruited” by Jane Doe No. 16’s tennis
her tennis instructor to “play tennis” coach was employed by the
with Nygard at Nygard Cay when she Nygard Companies and
was nineteen years old. Jane Doe No. “recruited” Jane Doe No. 16
16’s tennis instructor referred to for Nygard.
Nygard as “boss.”
The Nygard Companies paid
During one visit to Nygard Cay, Jane for Nygard’s commercial
Doe No. 16 was drugged, raped, and sex acts with Jane Doe No.
sodomized by Nygard. Nygard then 16.
provided Jane Doe No. 16 to his
friends, in exchange for something of
value, who also raped and sodomized
her. Nygard threw money at her
afterwards.
19 17 Jane Doe No. 17 and a friend were All employees that worked
invited to dinner at Nygard’s Marina the dinner were paid by the
Del Rey property when she was Nygard Companies.
nineteen years old.
The Nygard Companies paid
At dinner, Jane Doe No. 17 was for the drugs that were used
drugged. Nygard took her to a to drug Jane Doe No. 17.
bedroom and raped her.
32
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 33 of 270
16 19 Jane Doe No. 19 attended a “party” at Jane Doe No. 19 was raped
the Nygard Companies’ Toronto office at the Nygard Companies’
with one of Nygard’s recruiters who Toronto office.
was her boyfriend at the time. Only
Nygard and one other girl were there. Nygard enticed and lured
Jane Doe No. 19 was sixteen years old. Jane Doe No. 19 with
modeling offers with the
Nygard took Jane Doe No. 19 and Nygard Companies as well
another young female into a bedroom as trips on the corporate jet.
with his friend. Nygard gave Jane Doe
No. 19 alcohol and drugged her. The Nygard Companies paid
Nygard raped Jane Doe No. 19 while for the alcohol and drugs
her boyfriend had sex with the other that were used to drug Jane
female. Doe No. 19.
20 20 Nygard called Jane Doe No. 20, told Nygard used false promises
her she was beautiful, and invited her of a modeling opportunity
to the Nygard Companies Toronto with the Nygard Companies
office to discuss a modeling to lure Jane Doe No. 20 to
opportunity with the Nygard the Bahamas.
Companies.
The Nygard Companies paid
Nygard showed various fabric samples for Jane Doe No. 20 to
to Jane Doe No. 20 and discussed travel to the Bahamas.
modeling for the Nygard Companies.
Nygard told Jane Doe No. 20 that he
33
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 34 of 270
had a modeling job for her in the Jane Doe No. 20’s travel
Bahamas. was booked and paid for by
While at Nygard Cay in the Bahamas, a Nygard Companies’
Nygard raped, sodomized and employee through Nygard’s
penetrated Jane Doe No. 20 with an travel agent.
object on multiple occasions. He would
not let her leave the compound until The Nygard Companies
the date her return flight was booked arranged to have Jane Doe
for arrived. No. 20 picked-up from the
airport in a limousine.
Adult 21 Jane Doe No. 21 met Nygard at a Nygard used false promises
charity event. Nygard told Jane Doe of a modeling opportunity
No. 21 that she was beautiful and that with the Nygard Companies
he would like her to model for the to lure Jane Doe No. 21 to
Nygard Companies. Nygard invited his Marina Del Rey
Jane Doe No. 21 to stay at his Marina property.
Del Rey residence to further discuss Nygard used his
modeling for the Nygard Companies, housekeeper, paid by the
to which she agreed. Nygard Companies, to lure
Jane Doe No. 21 to his
While at the Marina Del Rey residence, bedroom.
Nygard’s housekeeper told Jane Doe
No. 21 that Nygard wanted to see her.
Nygard forcibly performed oral sex on
Jane Doe No. 21 and raped her.
34
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 35 of 270
19 24 Jane Doe No. 24 met Nygard on an Nygard lured Jane Doe No.
airplane when she was working as a 24 to his Marina Del Rey
flight attendant. Jane Doe No. 24 and property with a false
Nygard exchanged phone numbers. promise of a job opportunity
working for the Nygard
Nygard called Jane Doe No. 24 and Companies.
invited her to visit his home in Marina
Del Rey.
Adult 25 Jane Doe No. 25 worked as a model in Nygard made false promises
Los Angeles. Jane Doe No. 25 met to Jane Doe No. 25 of
Nygard at a night club in Hollywood. modeling opportunities for
Nygard told Jane Doe No. 25 that he the Nygard Companies.
wanted her to model for the Nygard
Companies. The Nygard Companies paid
Nygard invited Jane Doe No. 25 and for Jane Doe No. 25 to
two of her friends to travel to Nygard travel to and from Nygard
Cay. Nygard attempted to make sexual Cay.
35
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 36 of 270
advances on Jane Doe No. 25 and her The “pamper party” that
friends. Nygard would not allow them Jane Doe No. 25 was raped
to leave the Nygard Cay property. at was a Nygard Companies
Eventually, they escaped and Nygard corporate event.
sent them home.
All employees that worked
Later that year, Jane Doe No. 25 the “pamper party” were
attended a “pamper party” at Nygard’s paid by the Nygard
Marina Del Rey home. She thought Companies.
she would be safe because it was a
large gathering of people. Nygard The Nygard Companies paid
drugged and sodomized Jane Doe No. for the supplies, food, and
25 at the “pamper party.” alcohol at the “pamper
party.”
Adult 26 Jane Doe No. 26 was “recruited” by a Nygard lured and enticed
mutual friend of hers to meet Nygard Jane Doe No. 26 with false
for a potential modeling opportunity promises of a modeling
with the Nygard Companies. Nygard opportunity with the Nygard
met and “approved” Jane Doe No. 26 Companies.
for modeling with the Nygard The Nygard Companies paid
Companies. for Jane Doe No. 26 to
travel to and from the
The Nygard Companies flew Jane Doe Bahamas.
No. 26 to Nygard Cay under the guise
of a modeling photo shoot. After Jane
Doe No. 26 arrived, she was not
permitted to leave the property.
Adult 27 Jane Doe No. 27 met Nygard at the Nygard sexually battered
Nygard Companies’ Winnipeg office. Jane Doe No. 27 at the
Jane Doe No. 27 was seeking a Nygard Companies’
modeling sponsorship. corporate office in
During her meeting with Nygard, Winnipeg.
Nygard told Jane Doe No. 27 that she
was beautiful and asked her to travel Nygard attempted to use the
the world with him. Nygard then Nygard Companies brand
groped Jane Doe No. 27’s breasts. and promises of glamorous
36
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 37 of 270
Jane Doe No. 27 fled the office and trips to lure and entice Jane
was able to escape. Doe No. 27 into commercial
sex acts.
Adult 28 Jane Doe No. 28 was working as a Nygard lured and enticed
model in California. Nygard saw a Jane Doe No. 28 with false
picture of her and invited her to travel promises of a modeling
to Toronto to discuss a modeling opportunity with the Nygard
opportunity with the Nygard Companies.
Companies.
The Nygard Companies paid
Jane Doe No. 28 was picked-up at the for Jane Doe No. 28 to
airport by a car service paid for by the travel to Toronto.
Nygard Companies. The car took Jane
Doe No. 28 to Nygard’s home in Security guards employed
Toronto where other girls were also by the Nygard Companies
staying. Once she arrived, Jane Doe attempted to confiscate Jane
No. 28 was not permitted to leave the Doe No. 28’s passport.
property. Security guards employed by
the Nygard Companies attempted to
confiscate Jane Doe No. 28’s passport.
Adult 29 Jane Doe No. 29 was in the Bahamas Nygard lured and enticed
modeling for a calendar. Jane Doe No. Jane Doe No. 29 with false
29 met Nygard through her modeling promises of a modeling
sponsor. Nygard invited Jane Doe No. opportunity with the Nygard
29 to stay at Nygard Cay and proposed Companies.
a future modeling career with the
Nygard Companies. Jane Doe No. 29 booked
travel arrangements through
A few months later, Nygard called Jane the Nygard Companies, to
Doe No. 29 and told her that he had include flights and an
modeling work for her to do for the airport car service.
Nygard Companies. Jane Doe No. 29
booked travel arrangements through Jane Doe No. 29 was paid
the Nygard Companies, to include with cash from the Nygard
flights and an airport car service. Companies.
37
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 38 of 270
Adult 30 Jane Doe No. 30 was living in Los The “pamper party” that
Angeles and was working as manager Jane Doe No. 30 was raped
for models and actors. She met Nygard at was a Nygard Companies
through a modeling client. corporate event.
44 31 Jane Doe No. 31’s daughter was an Nygard lured and enticed
friend of one of Nygard’s children. Jane Doe No. 31, in part, by
Nygard called Jane Doe No. 31 and offering her a potential
invited her and her daughter to visit artistic opportunity for the
Nygard Cay because she had done the Nygard Companies at
Nygard family a favor. Additionally, Nygard Cay.
38
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 39 of 270
Adult 34 Jane Doe No. 34 was working as a The Nygard Companies paid
model and was taken to Nygard Cay by for the supplies, food, and
her modeling manager. While there, alcohol at the party.
Nygard attempted to enter Jane Doe
No. 34’s room in the middle of the
39
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 40 of 270
Adult 35 Jane Doe No. 35 was working as a Jane Doe No. 35 was
model for the Nygard Companies. working as a model for the
Nygard called Jane Doe No. 35 and Nygard Companies.
invited her to visit Nygard Cay.
The Nygard Companies paid
One night, Nygard asked Jane Doe No. for Jane Doe No. 35 to
35 to come up to his bedroom. Nygard travel to Nygard Cay.
then forcibly raped her. The next day,
a male employee of the Nygard A Nygard Companies’
Companies placed Jane Doe No. 35’s employee packed Jane Does
bags in a jeep and drove her to the bags and dropped her off at
middle of nowhere. a bus stop in the middle of
nowhere.
40
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 41 of 270
Nygard let Jane Doe No. 36 out of the Jane Doe No. 36 was raped
room and she walked through the in a room located at the
Nygard Companies’ office building to Nygard Companies’ office
leave. A Nygard Companies’ security building.
guard had to let her out. Jane Doe No.
36 told the security guard what Jane Doe No. 36 told the
happened, but he did nothing. security guard that worked
for the Nygard Companies
that she was raped. The
security guard did nothing.
15 37 Jane Doe No. 37’s father was in the fur Nygard targeted Jane Doe
business and sold Nygard furs. Jane No. 37 because he
Doe No. 37 worked in her father’s frequented her father’s fur
store and frequently saw Nygard at the store to purchase furs for the
store. Nygard Companies.
41
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 42 of 270
Adult 38 Jane Doe No. 38 met Nygard at a party Nygard lured and enticed
in Los Angeles, California. Nygard Jane Doe No. 38 with false
told Jane Doe No. 38 that she was promises of a modeling
beautiful and that she should model for opportunity with the Nygard
the Nygard Companies. Nygard Companies.
insisted on Jane Doe No. 38 coming to
his Marina Del Rey property to discuss A Nygard Companies’ limo
modeling for the Nygard Companies. took Jane Doe No. 38 to the
Nygard sent a limo to pick Jane Doe Marina Del Rey property.
No. 38 up and drive her to his Marina
Del Rey residence. In the limo, videos The Nygard Companies
of Nygard and the Nygard Companies provided the cash that was
fashion awards were playing on TV given to Jane Doe No. 38.
screens.
The Nygard Companies paid
After Jane Doe No. 38 arrived, Nygard for the drugs that were used
took her to dinner and a night club. to drug Jane Doe No. 38.
Nygard spiked Jane Doe No. 38’s drink
with drugs at the night club. On the
way home Jane Doe No. 38 blacked
out. She woke up on a bed at the
Marina Del Rey property and Nygard
was on top of her raping her.
Adult 39 Jane Doe No. 39 was walking down the Jane Doe No. 39 was
street in New York City when an employed as a model for the
employee of the Nygard Companies Nygard Companies.
approached her and told her about a
modeling job for the Nygard A Nygard Companies
Companies’ store. Jane Doe No. 39 employee “recruited” Jane
took the job and modeled for the Doe No. 39 for Nygard.
42
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 43 of 270
Adult 40 Jane Doe No. 40 was hired to work as Jane Doe No. 40 was
an employee of the Nygard Companies. employed by the Nygard
Companies.
Nygard contacted Jane Doe No. 40 and
requested that she travel to Nygard Nygard lured, enticed, and
Cay. While at Nygard Cay, Nygard coerced Jane Doe No. 40,
spiked Jane Doe No. 40’s drink with through her employment
drugs and sodomized her. with the Nygard Companies,
to travel to Nygard Cay
When Jane Doe No. 40 confronted where he sodomized her.
Nygard, he threatened that she would
“go in the water” if she told anyone, The Nygard Companies paid
which she understood was a threat to for Jane Doe No. 40 to
her life. travel to Nygard Cay so that
Nygard could sodomize her.
Adult 41 Jane Doe No. 41 is a former employee The “pamper party” and
of the Nygard Companies, to include subsequent boat party that
working in ComCor. Jane Doe No. 41 was raped
at was a Nygard Companies
corporate event.
43
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 44 of 270
Jane Doe No. 41 first met Nygard at a All employees that worked
“pamper party,” where she was the “pamper party” were
encouraged to drink heavily. The party paid by the Nygard
moved to Nygard’s boat. Jane Doe No. Companies.
41 was raped by Nygard and one of his
“girlfriends” on the boat and given The Nygard Companies paid
approximately $500 in U.S. currency. for the supplies, food, and
alcohol at the “pamper
Jane Doe No. 41 was friends with one party.”
of Nygard’s “girlfriends.” Jane Doe
No. 41’s friend got her a job working The Nygard Companies
at Nygard Cay for the Nygard provided the cash that
Companies because she needed the Nygard paid Jane Doe No.
money. Jane Doe No. 41 eventually 41 after he raped her.
took on other jobs and responsibilities
at Nygard Cay, to include ComCor. The Nygard Companies paid
to transport Jane Doe No. 41
Jane Doe No. 41 was told by Nygard to her home after the
that she would have to have sex with “pamper party.”
Nygard if she wanted to be paid for the
overtime she earned or the raise she Jane Doe No. 41 is a former
deserved as an employee of the Nygard employee of the Nygard
Companies. Companies, to include
working in ComCor.
Nygard threatened Jane Doe No. 41 to
force her to introduce other women to Nygard told Jane Doe No. 41
him and stated a preference for that she would not be paid
“younger” girls. for the overtime she earned
or the raise she deserved as
Jane Doe No. 41 frequently travelled an employee of the Nygard
with Nygard and others to Florida, Companies unless she
New York, and California. agreed to have sex with him.
He also withheld her pay for
Nygard raped Jane Doe No. 41 at his the same.
New York City office/apartment. Jane Doe No. 41 travelled
Nygard also coerced Jane Doe No. 41 with Nygard to New York
to have sex with Nygard and other City and Florida, where
women by threatening to withhold her Nygard raped her.
income or fire her.
The driver, employed by the
Jane Doe No. 41 had to attend the Nygard Companies, drove
“swingers club” with Nygard and his Nygard, Jane Doe No. 41,
other “girlfriends.” The driver, and the others to the
employed by the Nygard Companies, “swingers club.”
drove the group to the “swingers club.”
44
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 45 of 270
Nygard also raped Jane Doe No. 41 Nygard used Jane Doe No.
while they were staying at the W Hotel 41’s employment with the
in Ft. Lauderdale, Florida. Nygard Companies as a
means to coerce her into sex
Nygard sent Jane Doe No. 41 to acts with Nygard and other
retrieve cash out of his safe when he women.
had important political contacts over
for dinner. Jane Doe No. 41 witnessed Nygard used money from
Nygard use this money, paid by the the Nygard Companies to
Nygard Companies, to bribe Bahamian bribe Bahamian public
public officials, politicians, or high- officials, politicians, or
ranking police officers. On other high-ranking police officers.
occasions, Jane Doe No. 41 witnessed He also offered his
Nygard offer public officials, “girlfriends,” who were paid
politicians, or high-ranking police by the Nygard Companies,
officers one of his “girlfriends” for to officials, politicians, or
sexual gratification as payment. high-ranking police officers
for sexual gratification as a
bribe.
18 42 Jane Doe No. 42 was lured and enticed Jane Doe No. 42 was lured
to the Nygard Companies’ Toronto and enticed to the Nygard
office by Nygard through a promise of Companies’ Toronto office
a modeling opportunity for the Nygard by Nygard through a
Companies. promise of a modeling
opportunity for the Nygard
Jane Doe No. 42 modeled some Companies.
clothing for the Nygard Companies at
the companies’ Toronto office. Nygard raped and
Afterwards, Nygard offered Jane Doe sodomized Jane Doe No. 42
No. 42 a “tour” of the office. Nygard at the Nygard Companies’
took Jane Doe No. 42 into a dark room Toronto property.
and closed the door. The room had a
bed in it and Nygard pushed Jane Doe
No. 42’s head on the bed and forcefully
raped and sodomized her.
Adult 43 Jane Doe No. 43 came to Nygard’s Jane Doe No. 43 was lured
Marina Del Rey property to sign a and enticed to Nygard’s
modeling contract for the Nygard Marina Del Rey property
Companies. under the guise of signing a
modeling contract for the
Shortly after signing the contract, Nygard Companies.
Nygard followed Jane Doe No. 43 into
the bathroom and raped her. After the rape, Nygard
bought Jane Doe No. 43 a
45
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 46 of 270
Adult 45 Jane Doe No. 45 was approached by a Jane Doe No. 45 was lured
woman who identified herself as a and enticed to Nygard’s
talent agent. The woman told Jane Doe Marina Del Rey property
No. 45 that she could be a model. In under the guise of signing a
actuality, the woman was a “madame” modeling contract for the
who sex trafficked young women. Nygard Companies.
The woman told Jane Doe No. 45 that The “pamper parties” that
she could introduce her to Nygard, who Jane Doe No. 45 was
was a multi-millionaire, fashion sexually assaulted at were
designer. The woman told Jane Doe Nygard Companies
No. 45 that Nygard could give her a corporate events.
modeling career.
46
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 47 of 270
The woman took Jane Doe No. 45 to All employees that worked
“pamper parties” at Nygard’s Marina the “pamper parties” were
Del Rey property. Nygard paid the paid by the Nygard
“madame” for commercial sex acts Companies.
with Jane Doe No. 45 and coerced
and/or forced Jane Doe No. 45 to The Nygard Companies paid
engage in commercial sex acts. for the supplies, food, and
alcohol at the “pamper
parties.”
Adult 46 In approximately 2007, Jane Doe No. Nygard lured and enticed
46 was working as a runway model. Jane Doe No. 46 with false
She met Nygard through professional promises of modeling
contacts. Nygard offered her a opportunities with the
modeling opportunity for the Nygard Nygard Companies.
Companies in New York City.
The Nygard Companies paid
The Nygard Companies paid to fly for Jane Doe to travel to
Jane Doe No. 46 to New York City on New York City on the
Defendants’ “N-Force” jet and paid for corporate jet and paid for
her to stay at the W Hotel. her hotel room where she
was sexually assaulted by
While sleeping in her hotel room, Nygard.
Nygard entered and woke her up. He
told Jane Doe No. 46 that she was
beautiful and that she should model for
the Nygard Companies. Nygard then
demanded that Jane Doe No. 46
defecate in his mouth. When she
refused, he became enraged, forced her
to perform oral sex on him, and
forcibly performed oral sex on her.
Adult 47 Jane Doe No. 47 was pitched by a Jane Doe No. 47 attended a
modeling agent on going to a “pamper “pamper party” at Nygard’s
party” at Nygard’s Marina Del Rey Marina Del Rey home with
property with the understanding that the understanding that there
there was potential modeling was a modeling opportunity
opportunity with the Nygard with the Nygard Companies.
Companies.
47
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 48 of 270
At the “pamper party,” Jane Doe No. The “pamper party” that
47 was introduced to Nygard by the Jane Doe No. 47 was raped
modeling agent. Nygard took Jane at was a Nygard
Doe No. 47 on a tour of his home. Companies’ event and was
When they got to Nygard’s bedroom, paid for and staffed by the
Nygard pushed Jane Doe No. 47 on the Nygard Companies.
bed and forcefully raped her.
17 48 Jane Doe No. 48 met Nygard at a night Jane Doe No. 48 was raped
club in Winnipeg. Jane Doe No. 48 on Nygard Companies’
needed a ride home and Nygard offered property.
to drive her. Instead of driving Jane
Doe No. 48 home, Nygard took her to Nygard attempted to pay-off
the Nygard Companies Winnipeg Jane Doe No. 48 with funds
office. and resources of the Nygard
Companies.
While at the Winnipeg office, Nygard
took Jane Doe No. 48 to a lofted area
with a bed. Nygard forcefully raped
Jane Doe No. 48 at the Nygard
Companies’ Winnipeg office.
14 49 Jane Doe No. 49 met Nygard while Jane Doe No. 49 worked for
working for the Nygard Companies the Nygard Companies
during the summer of 1979. Jane Doe modeling clothes.
No. 49 modeled clothing for the
Nygard Companies. Nygard sexually assaulted
and/or battered Jane Doe
Nygard provided Jane Doe No. 49 with No. 49 at a property owned
alcohol even though she was only by the Nygard Companies.
fourteen years old. Nygard coerced
Jane Doe No. 49 to perform oral sex on Nygard had an employee of
him on numerous occasions. the Nygard Companies
serve as a “lookout” for him
On one occasion, Nygard digitally while he attempted to
penetrated Jane Doe No. 49’s vagina sexually batter and/or
and performed oral sex on her. assault Jane Doe No. 49.
18 50 In 1998, Jane Doe No. 50 was eighteen Nygard lured and enticed
years old and was an aspiring model. Jane Doe No. 50 with false
48
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 49 of 270
Adult 51 Jane Doe No. 51 is a former employee Jane Doe No. 51 was an
of the Nygard Companies from 2018- employee of the Nygard
2019. Companies.
In 2018, Nygard requested that Jane Jane Doe No. 51 was paid
Doe No. 51 travel to New York City. for commercial sex acts by
It was arranged for Jane Doe No. 51 to the Nygard Companies
stay at Nygard’s apartment located on corporate accountant.
the sixth floor of the Nygard
Companies’ world headquarters. The Nygard Companies paid
Nygard raped Jane Doe No. 51 at his for Jane Doe No. 51 to
apartment. Nygard also forced Jane travel to locations where
Doe No. 51 to attend “swingers clubs” Nygard forced her to
in New York City, where he sex perform commercial sex
trafficked her to other men. acts, and trafficked her to
other men.
Nygard also trafficked and/or
attempted to traffic Jane Doe No. 51 in Jane Doe No. 51 was raped
Florida, Canada, California, Alaska, by Nygard at Nygard’s
Panama, and the Middle East. penthouse apartment located
on the sixth floor of the
Nygard Companies’ world
headquarters.
Adult 52 In 2019, Jane Doe No. 52 met Nygard Nygard lured and enticed
while attending “pamper parties” at Jane Doe No. 52 to his
Defendants’ Marina Del Rey property. property with “pamper
parties” staffed and funded
At one of the “pamper parties” Nygard by the Nygard Companies.
asked Jane Doe No. 52 if she modeled.
49
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 50 of 270
Nygard told Jane Doe No. 52 that she Nygard lured, enticed, and
should come to “pamper parties” more coerced Jane Doe No. 52
often. Nygard also indicated that she with false promises of
could potentially get a job with the modeling and/or career
Nygard Companies. opportunities with the
Nygard Companies.
Nygard offered to show Jane Doe No.
52 a tour of the Marina Del Rey Nygard lured and enticed
property. Nygard gave her $500 and Jane Doe No. 52 with cash
claimed it was for transportation costs. provided by the Nygard
While on the tour Jane Doe No. 52 Companies.
used the bathroom. When she walked
out of the bathroom Nygard was naked
in the bed. Nygard began rubbing his
penis up against her. He then shoved
her down, digitally penetrated her anus,
and vaginally raped her.
Adult 53 In approximately 1977, Jane Doe No. The Nygard Companies paid
53 was on a flight from California to for the dinner that Jane Doe
Winnipeg, Canada. Nygard was on the No. 53 had with Nygard.
same flight and approached Jane Doe
No. 53 and they began talking. Nygard The Nygard Companies paid
asked for Jane Doe No. 53’s phone for the hotel room where
number and eventually called her to go Jane Doe No. 53 was raped
on a date. and/or sexually battered.
Adult 54 Jane Doe No. 54 worked as a child Jane Doe No. 54’s flights to
model in Florida. In January and April the Bahamas were booked
2010, Jane Doe No. 54 was lured and through the Nygard
enticed by one of Nygard’s Companies’ corporate travel
department.
50
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 51 of 270
14 55 In 1980, Jane Doe No. 55 met Nygard Nygard lured and enticed
in California when she was 14-15 years Jane Doe No. 55 with funds
old. Nygard lured and enticed Jane and/or gifts purchased with
Doe No. 55, who was a run-away, to funds from the Nygard
move-in with him at his home in Playa Companies.
Del Rey, California.
Nygard used funds from the
Throughout her time staying with Nygard Companies to pay
Nygard, Nygard had sexual intercourse for Jane Doe No. 55 to
with Jane Doe No. 55, a minor, on travel with him to fashion
numerous occasions. Nygard also sex shows.
trafficked Jane Doe No. 55 to
approximately 100 individuals. Nygard used funds from the
Nygard Companies to pay
for Jane Doe No. 55 to
attend modeling school.
18 56 In 1980, when she was eighteen years Nygard raped Jane Doe No.
old, Jane Doe No. 56 met Nygard at a 56 at the Nygard
night club in Winnipeg, Canada. Jane Companies’ building in
Doe No. 56 was taken to the Nygard Winnipeg, Canada.
Companies’ building in Winnipeg.
51
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 52 of 270
Adult 57 Jane Doe No. 57 met Nygard in 2007 The Nygard corporate travel
when she was twenty-two years old department paid and
and was working as a model. arranged for Jane Doe No.
57 to travel to New York
In 2009, the Nygard Companies’ City, where Nygard
corporate travel department arranged trafficked her to other men
and paid for Jane Doe No. 57 to travel at “swingers clubs.”
to New York City to meet with Nygard
and engage in commercial sex acts Nygard trafficked Jane Doe
with him. No. 57 to another man at his
New York City apartment
In approximately 2010 or 2011, above the Nygard
Nygard trafficked Jane Doe No. 57 to Companies’ World
have sex with another man at Nygard’s Headquarters.
New York City apartment.
The Nygard Companies paid
From 2009-2014, Nygard also coerced for Jane Doe No. 57 to stay
Jane Doe No. 57 to go to “swingers at the W Hotel in New York
clubs” with him on several occasions in City.
New York City. While at the “swingers
clubs” Nygard coerced Jane Doe No. Jane Doe No. 57 was paid
57 to have sex with other men against for coerced commercial sex
her will on multiple occasions. acts with Nygard with U.S.
currency from the Nygard
Companies.
42. Nygard’s conduct, as outlined above, violates the TVPRA, which outlaws using
means of interstate or foreign commerce to recruit, entice, obtain, or lure a person and force or
coerce that person, or knowing that the person had not attained the age of eighteen years, to engage
in commercial sex acts. Nygard’s conduct also violates various other state and foreign laws,
including the laws of California, Florida, Canada, and the United Kingdom. The Nygard
Companies are guilty of aiding and abetting Nygard’s crimes and conspiring with Nygard to
violate the TVPRA and these other state and foreign laws by knowingly agreeing to facilitate and
enable his illegal conduct for their own gain and their employees’ gain.
43. The Nygard Companies also directly violated the TVPRA and these other state and
foreign laws because they knowingly benefitted from their conspiracy and/or participation in
52
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 53 of 270
Nygard’s venture with knowledge, or in reckless disregard of the fact, that Nygard used means of
force, threats of force, fraud, and coercion to force children and women into engaging in
44. This Court has federal question subject-matter jurisdiction pursuant to 28 U.S.C. §
1331, because Plaintiffs bring this action—individually and on behalf of the other Class
45. This Court also has supplemental jurisdiction pursuant to 28 U.S.C. § 1367(a),
because all claims alleged herein are part of a continuing conspiracy and uniform pattern and
46. Plaintiffs Jane Does Nos. 1-57’s claims arise out of the same series of transactions
or occurrences and share common questions of law or fact. The essential facts of Jane Doe Nos.
1-57’s claims are so logically connected that considerations of judicial economy and fairness
dictate that all the issues be resolved in a single lawsuit. There is also substantial overlap in
47. This Court is “an appropriate district court of the United States” in accordance with
18 U.S.C. § 1595, as venue is proper in this District under 28 U.S.C. § 1391(b)(2), because Nygard,
with the help of the Nygard Companies, raped, sexually assaulted, sexually battered, molested,
and/or sex trafficked some of his victims, including Jane Does Nos. 12, 13, 39, 41, 46, 51, and 57
in this District. Nygard Inc. and Nygard International, both headquartered near Times Square in
New York City, also conduct substantial activities in this District and knowingly conspired, aided
and abetted, facilitated, and directly participated in Nygard’s illegal conspiracy and/or venture
through actions that originated in this District. Venue is also proper in this District under 28 U.S.C.
53
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 54 of 270
§ 1391(b)(3), because all Defendants conduct substantial activities in this District and are subject
to personal jurisdiction in this District and there is no other district where the action may be
brought.
PARTIES
A. Plaintiffs
48. Plaintiffs Jane Does Nos. 1-57 are using pseudonyms to protect their identities
49. Plaintiffs are also at serious risk of retaliatory harm because Defendants have
tremendous wealth and power and have used it to retaliate against others who have attempted to
come forward, including by means of arson, property destruction, and threats of physical violence.
50. Plaintiffs are also particularly vulnerable because of the trauma that they have been
subjected to, their socioeconomic status, Defendants’ wealth and influence in the Bahamas,
Canada, and the United States, and the corruption of local law enforcement by Defendants through
51. Plaintiffs’ safety, right to privacy, and security outweigh the public interest in their
identification.
53. Jane Doe No. 1 is a Bahamian citizen, born in Nassau, New Providence, the
Bahamas. In July 2015, Jane Doe No. 1 was vaginally raped by Nygard at the age of fourteen,
while attending a “pamper party” at Nygard Cay. Nygard lured her to his bedroom under false
20
See, e.g., https://www.youtube.com/watch?v=Pw1xUXQNelg;
http://www.tribune242.com/news/2018/feb/14/nygard-outright-bribery-plp/;
http://www.tribune242.com/news/2014/jun/25/nygard-gave-money-plp-then-asked-help-over-land-is/;
http://www.tribune242.com/news/2017/may/05/fresh-questions-over-las-vegas-trip-pm-gibson-and-/
54
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 55 of 270
promises of a future modeling contract. Following the rape, she was paid by Nygard in U.S.
currency from the Nygard Companies. She never returned to Nygard Cay.
54. Jane Doe No. 2 is a Bahamian citizen, born in Nassau, New Providence, the
Bahamas. In August and November 2011, Jane Doe No. 2 was vaginally raped by Nygard at the
age of fourteen, while attending “pamper parties” at Nygard Cay. She attended the “pamper
parties” and Nygard lured her to his bedroom under false promises of a future modeling contract.
Following the rape, Nygard paid her approximately $5,000 in U.S. currency from the Nygard
Companies. She attended several “pamper parties” at Nygard Cay subsequent to 2011, and Nygard
paid her with cash from the Nygard Companies to “recruit” and/or “procure” other young girls for
55. Jane Doe No. 3 is a Bahamian citizen, born in Nassau, New Providence, the
Bahamas. In June 2011, Jane Doe No. 3 was vaginally raped by Nygard at the age of fifteen, while
attending a “pamper party” at Nygard Cay. Jane Doe No. 3 was lured to Nygard Cay under false
promises of a job there. Following the rape, Nygard paid her approximately $200 in U.S. currency
56. Jane Doe No. 4 is a Bahamian citizen, born in Nassau, New Providence, the
Bahamas. In June 2011, Jane Doe No. 4 was vaginally raped by Nygard at the age of fourteen,
while attending a “pamper party” at Nygard Cay. Nygard lured Jane Doe No. 4 to his bedroom
under a false promise of a modeling contract. Following the rape, Nygard paid her approximately
$5,600 in U.S. currency from the Nygard Companies. She never returned to Nygard Cay.
57. Jane Doe No. 5 is a Bahamian citizen born, in Nassau, New Providence, the
Bahamas in August 1992. In July 2009, Jane Doe No. 5 was sodomized by Nygard at the age
sixteen, while attending a “pamper party” at Nygard Cay. Following the rape, Nygard paid her
55
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 56 of 270
approximately $200 in U.S. currency from the Nygard Companies. She never returned to Nygard
Cay.
58. Jane Doe No. 6 is a Bahamian citizen, born in Nassau, New Providence, the
Bahamas. In August 2008, Jane Doe No. 6 was vaginally raped by Nygard at the age of fifteen,
while attending a “pamper party” at Nygard Cay. Following the rape, Nygard offered her cash
from the Nygard Companies and she refused it. She never returned to Nygard Cay.
59. Jane Doe No. 7 is a Bahamian citizen. In 2010, Jane Doe No. 7 was sodomized by
Nygard at the age of eighteen, while attending a “pamper party” at Nygard Cay. Following the
rape, Nygard paid her approximately $550 in U.S. currency from the Nygard Companies. She
60. Jane Doe No. 8 is a Bahamian citizen. In 2014, Jane Doe. No. 8 was vaginally
raped by Nygard at the age of 29 or 30, while serving as an employee at Nygard Cay. Following
the rape, Nygard offered her cash in U.S. currency from the Nygard Companies. She was
terminated from her employment when she refused to continue engaging in sexual relations on an
ongoing basis with Nygard. Between April 6, 2017 and April 10, 2017, Nygard caused Jane Doe
61. Jane Doe No. 9 is a United States citizen. She was an employee of Nygard and the
Nygard Companies. Throughout her time as an employee of Nygard and the Nygard Companies,
she was sexually assaulted by Nygard on multiple occasions. In 2015, Nygard forcefully raped
Jane Doe No. 9 at his residence in Marina Del Ray, California. Nygard used her continued
employment with and payment by the Nygard Companies as a means to control and coerce Jane
56
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 57 of 270
62. Jane Doe No. 10 is a Bahamian citizen, born in Nassau, New Providence, the
Bahamas. In the summer of 2004, when Jane Doe No. 10 was fifteen years old, she was drugged
and vaginally and sodomized, by Nygard while attending a “pamper party.” Nygard offered her
$5,000 prior to raping her and later offered her $10,000 to defecate in his mouth.
63. Jane Doe No. 11 is a Bahamian citizen. In 2002 or 2003, when Jane Doe No. 11
was fifteen years old, she was raped by Nygard while attending a “pamper party.” Nygard also
demanded that she defecate and urinate on him. From 2005-2008, Jane Doe No. 11 became a
regular sex partner of Nygard because she was an orphan and Nygard falsely promised her a job
64. Jane Doe No. 12 is a Bahamian citizen. Jane Doe No. 12 was first invited to a
“pamper party” at Nygard Cay in 2008. Nygard gave Jane Doe No. 12 a “tour” of the property,
which ended in his bedroom. Without getting her consent, he initiated sexual activity with her and
demanded that Jane Doe No. 12 defecate in his mouth. Afterwards, Nygard paid Jane Doe No. 12
between $500 and $1,000 in United States currency. Jane Doe No. 12 became one of Nygard’s
regular “girlfriends,” meaning that the Nygard Companies paid her monthly to engage in
commercial sex acts and “recruit” victims for Nygard. Jane Doe No. 12 travelled with Nygard as
a “girlfriend” to New Orleans, Los Angeles, New York City, China, and London. Without her
consent, Nygard provided and offered Jane Doe No. 12 to other men for commercial sex acts in
Los Angeles and New York City in exchange for something of value.
65. Jane Doe No. 13 is a Canadian citizen. In 2007, Jane Doe No. 13 was seventeen
years old and travelled to New York City to meet her new modeling manager and pursue a
modeling career. The modeling manager “recruited” and groomed Jane Doe No. 13 for Nygard.
The modeling manager drove her to Nygard’s New York City apartment and introduced her to
57
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 58 of 270
Nygard. Nygard Companies’ employees and the modeling manager encouraged Jane Doe No. 13,
a minor, to drink alcohol, which was spiked with drugs. Jane Doe No. 13 was brought into the
bedroom where Nygard was waiting. Jane Doe No. 13 shortly thereafter she lost consciousness
and awoke face down on a bed vomiting while Nygard sodomized and raped her.
66. Jane Doe No. 14 is a Canadian citizen. In approximately 2003, Jane Doe No. 14
was “recruited” by a current employee of the Nygard Companies for a job opportunity in the
Bahamas or in New York City. Jane Doe No. 14 applied and then went to the Nygard Toronto
office under the guise of job interview for the position with the Nygard Companies. While at
Defendants’ Toronto office, an employee of Defendants and/or “girlfriend” drugged Jane Doe No.
14 and during the interview, Nygard raped her in the bedroom located at the office. Jane Doe No.
14 woke up in the basement of the Toronto office where the same “girlfriend” and two other young
women were being held. Nygard, through the “girlfriend,” released Jane Doe No. 14 only after he
was satisfied that she would not report his crimes, including taking the job in New York. Jane Doe
No. 14 travelled to New York City on the Defendant’s “N-Force” Jet and was put in a room at the
W Hotel in Time Square under the guise of starting a new job. Nygard attempted to victimize Jane
Doe No. 14 again, but was unsuccessful because she snuck out of the hotel.
67. Jane Doe No. 15 is a Canadian citizen. In 1993, Jane Doe No. 15 was twenty years
old and was contacted by Nygard and offered a modeling opportunity. The Nygard Companies
paid to fly Jane Doe No. 15 to Winnipeg, Canada. She was told she would be staying in the Nygard
Companies’ “executive suites.” When she arrived, she was unknowingly escorted to Nygard’s
personal apartment, which was attached to the Nygard Companies’ warehouse. He held her there
against her will for three days and raped her numerous times. Jane Doe No. 15 was eventually
58
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 59 of 270
able to escape. She wanted to report Nygard to the Winnipeg police, but did not out of fear because
68. Jane Doe No. 16 is a Canadian citizen. In 1998, when she was nineteen years old
and staying in the Bahamas, Jane Doe No. 16 was “recruited” by her tennis instructor to “play
tennis” with Nygard at Nygard Cay. Nygard invited Jane Doe No. 16 to stay at Nygard Cay on
another occasion and offered her a personal “cabana,” which was like guest quarters. While at
Nygard Cay, Jane Doe No. 16 was drugged, raped, and sodomized by Nygard. Nygard then
provided Jane Doe No. 16 to a group of friends who continued to rape and sodomize her. After
the rapes, Nygard threw cash at her. Nygard forced her to participate in a “swingers” sexual
69. Jane Doe No. 17 is a United States. In 1999, Jane Doe No. 17 was nineteen years
old and was invited to dinner by Nygard at his Marina Del Rey, California property. While at the
Marina Del Rey property, Nygard stated several comments about Jane Doe No. 17’s physical
appearance, such as that she was “so pretty and black,” she looked “so young,” and he called her
“a newbie.” Jane Doe No. 17 was drugged and raped by Nygard. Following the rape, she left the
property. The next day, Nygard offered her a free massage, nail treatment, and strawberries. He
told her that “things happen” and “you just got drunk.”
70. Jane Doe No. 18 is a United States citizen. In 1977, Jane Doe No. 18 was nineteen
years old and was raped by Nygard in Montreal, Canada. Nygard’s business associate approached
Jane Doe No. 18 at the airport after a flight from New York City to Montreal. He offered Jane
Doe No. 18 a ride to her dormitory on behalf of Nygard. During the car ride, Nygard insisted on
dropping his luggage off at his apartment. He invited Jane Doe No. 18 up to his apartment. After
she agreed, he forcefully raped her. After the rape, Nygard offered to buy Jane Doe No. 18 jewelry.
59
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 60 of 270
71. Jane Doe No. 19 is a Canadian citizen. In 2004-2005, when she was 16 years old,
Jane Doe No. 19 attended a party at a property owned by Defendants in Toronto with a boyfriend,
who was, unbeknownst to Jane Doe No. 19, a Nygard “recruiter.” What was supposed to be a
party was only four people: Jane Doe No. 19, her boyfriend, Nygard, and a young Bahamian girl.
Nygard told Jane Doe No. 19 that she was beautiful and could be a model. Nygard offered to show
the group around the property. Nygard escorted them into a bedroom and began to pour them
drinks and drugged Jane Doe No. 19’s drink. Jane Doe No. 19 began to feel foggy and Nygard
raped her, while instructing her boyfriend to join in. At the end, Jane Doe No. 19 was throwing
up and became unconscious before leaving. The next morning, the Bahamian girl called Jane Doe
No. 19, told her to check for the “Plan B” pills that had been given to her, and gave her instructions
72. Jane Doe No. 20 is a Canadian citizen. In approximately 1995, Nygard invited Jane
Doe No. 20, who was approximately twenty years old, to Defendants’ office in Toronto and told
her he wanted her to model for the Nygard Companies. Several days later, an employee of the
Nygard Companies invited Jane Doe No. 20 to Nygard Cay under the guise of a modeling job.
While at Nygard Cay, Nygard raped, sodomized, and penetrated Jane Doe No. 20 with an object
multiple times. Jane Doe No. 20 begged to leave the Nygard Cay property, but Nygard would not
allow her to leave. Nygard eventually booked Jane Doe No. 20 a return plane ticket, through the
73. Jane Doe No. 21 is a Canadian citizen. In 1988, Jane Doe No. 21 met Nygard in
Toronto at charity event where she was working as a volunteer model. Nygard told Jane Doe No.
21 that she was beautiful and that he wanted her to model for the Nygard Companies. Nygard
invited Jane Doe No. 21 to stay at his Marina Del Rey property and she agreed because she thought
60
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 61 of 270
it would be a good career opportunity. While at the Marina Del Rey property, Jane Doe No. 21
was told that Nygard wanted to see her by a housekeeper. When she got to his room, Nygard
74. Jane Doe No. 22 is a Canadian citizen. In 1977, Jane Doe No. 22 was twenty-seven
years old and was working for a textile company that did business with the Nygard Companies.
She met Nygard on an airplane on the way to a trade show in Frankfurt, Germany. Nygard noticed
Jane Doe No. 22 on the plane, walked down the aisle, and handed her a rose with a business card
attached. The two subsequently ran into each other at the trade show and then Nygard later invited
Jane Doe No. 22 to have a business dinner with him when they would both be in London, England
a few days later. After dinner, Nygard rode with Jane Doe No. 22 to her hotel and then walked
her to her door. When they reached the door Nygard pushed her into the room and attacked her.
He pulled her pantyhose down partially to immobilize her legs, forcibly performed oral sex on her,
and then masturbated over her until he orgasmed. Afterwards, both Jane Doe No. 22 and Nygard
fell asleep. When he awoke, he again forcibly engaged in oral sex with Jane Doe No. 22 and raped
her.
75. Jane Doe No. 23 is Canadian citizen. In approximately 1989-1990, Jane Doe No.
23 was thirty-two years old and was working as a performer in the Bahamas. She met Nygard in
the Bahamas. One evening, Nygard offered to drive Jane Doe No. 23 home from an event.
Nygard, however, passed Jane Doe No. 23’s home and took her to Nygard Cay. While at Nygard
Cay, he locked Jane Doe No. 23 inside the compound. Nygard forced Jane Doe No. 23 to perform
oral sex on him. He then took her inside and attempted to vaginally rape her but was she was able
to stop him.
61
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 62 of 270
76. Jane Doe No. 24 is a United States citizen. In 1989, Jane Doe No. 24 was nineteen
years old and was working as a flight attendant. Jane Doe No. 24 met Nygard on a flight from
New York City to Los Angeles and they exchanged phone numbers. Nygard offered Jane Doe
No. 24 a job and invited her to his Marina Del Rey property. Nygard gave Jane Doe No. 24 a
“tour” of the property, which ended in his bedroom. While in the bedroom, Nygard raped Jane
77. Jane Doe No. 25 is a German citizen. In 1995, Jane Doe No. 25 was living in Los
Angeles, California and working as a model. She met Nygard at a night club in Hollywood.
Nygard told Jane Doe No. 25 that he had his eye on her for a modeling job with the Nygard
Companies. Jane Doe No. 25 attended a “pamper party” at Nygard’s Marina Del Rey property.
Jane Doe No. 25 was drugged and sodomized by Nygard. She did not report his crime because
she believed that Defendants would use their influence in the Los Angeles modeling industry to
78. Jane Doe No. 26 is a Canadian citizen. In approximately 1990-1991, Jane Doe No.
26 was offered a modeling job by Nygard for the Nygard Companies. The Nygard Companies
flew Jane Doe No. 26 to the Bahamas, under the guise of the modeling job, where she stayed at
the Nygard Cay property. Nygard raped Jane Doe No. 26 on multiple occasions while at Nygard
Cay.
79. Jane Doe No. 27 is a Canadian citizen. In 1980, Jane Doe No. 27 was selected to
travel to Los Angeles, California for a beauty pageant. Jane Doe No. 27 visited Nygard at his
office in Winnipeg with her mother to discuss a potential modeling sponsorship. While her mother
waited in the car, Jane Doe No. 27 went into Nygard’s office to discuss a sponsorship. Nygard
told Jane Doe No. 27 she was beautiful asked her if she wanted to travel the world with him.
62
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 63 of 270
Nygard looked at Jane Doe No. 27’s modeling portfolio and said “nice eyes, nice lips.” Nygard
then approached Jane Doe No. 27, groped her left breast, and said “cute you must be a size 5.”
Jane Doe No. 27 fled the office and discovered that everyone was gone and the doors were locked.
She managed to find a janitor with keys to unlock the door and escaped.
80. Jane Doe No. 28 is a United States citizen. In approximately 2010, Jane Doe No.
28 was thirty-seven years old and was working as a model in Los Angeles, California. Nygard
saw a picture of Jane Doe No. 28 and offered to fly her to Toronto for a modeling opportunity with
the Nygard Companies. Upon arrival, she took a taxi to Nygard’s home in Toronto where several
other girls were staying. They showed her to her room. She was not permitted to leave the property
and a security guard employed by the Nygard Companies attempted to confiscate her passport. On
the second day staying at Nygard’s home, he forcibly sodomized Jane Doe No. 28. Nygard forced
Jane Doe No. 28 to go out with him at night to the “swingers club” in Toronto as well. A few days
later, Jane Doe No. 28 was flown to New York City with Nygard and all the other girls at the
house. Jane Doe No. 28 was able to escape once she got to New York.
81. Jane Doe No. 29 is a United States citizen. In approximately 1997, Jane Doe No.
29 was taken to the Bahamas by her modeling sponsor for a calendar photoshoot. She met Nygard
in a casino while in the Bahamas. Nygard invited her to come to Nygard Cay. Jane Doe No. 29’s
sponsor explained who Nygard was and told her that it could be her big chance. Jane Doe No. 29
went to Nygard Cay with Nygard. Nygard talked with Jane Doe No. 29 about modeling for the
Nygard Companies. A couple of months later Nygard called Jane Doe No. 29 and invited her to
stay with him at Nygard Cay to discuss modeling. Nygard raped Jane Doe No. 29 several times
while she was at Nygard Cay. After two trips to Nygard Cay, where Nygard raped Jane Doe No.
29 on numerous occasions, Nygard convinced her to travel to Marina Del Rey by continuing to
63
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 64 of 270
promise modeling opportunities. Nygard raped Jane Doe No. 29 while at the Marina Del Rey
property on several occasions. Nygard paid Jane Doe No. 29 $700 in U.S. currency before she left.
82. Jane Doe No. 30 is British citizen. In approximately 2000, Jane Doe No. 30 was
working as a manager for models and actors in Los Angeles, California. She was introduced to
Nygard by a client who was a model. She attended several “pamper parties” at Nygard’s Marina
Del Rey property. On one occasion, Jane Doe No. 30’s champagne was spiked with drugs. Jane
Doe No. 30 went to the bathroom to change after receiving a massage. When she walked out of
the bathroom, Nygard was waiting in the room. He pulled down his pants, began lubricating
himself, and had an erection. He pushed her onto the bed, attempted to sodomize her, and
penetrated her. She pushed him away, escaped into the bathroom, and locked the door until he
left.
83. Jane Doe No. 31 is a United States citizen. Jane Doe No. 31 knew Nygard through
her daughter who was friends with one of Nygard’s children. In 1998, Nygard invited Jane Doe
No. 31 and her daughter to go to Nygard Cay because they had done a favor for the Nygard family.
Additionally, Nygard lured Jane Doe No. 31 under the guise of an artistic opportunity at Nygard
Cay. While at Nygard Cay, Nygard violently forced Jane Doe No. 31 to perform oral sex on him.
84. Jane Doe No. 32 is Canadian citizen. In 2009, Jane Doe No. 32 was twenty-seven
years old and was brought to Nygard Cay to be a model in a photoshoot. Jane Doe No. 32 stayed
at Nygard Cay for 3-4 nights. Nygard’s “girlfriends” invited Jane Doe No. 32 to have drinks and
to party in a cabana hut. Nygard’s “girlfriends” spiked Jane Doe No. 32’s drink with drugs.
Nygard entered the room and began to touch Jane Doe No. 32’s legs and vaginal area, offering
money and a lavish lifestyle for sex. Jane Doe No. 32 turned Nygard down. After she left to use
64
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 65 of 270
the bathroom, the “girlfriends” gave her another drink and when she returned, she blacked out.
85. Jane Doe No. 33 is a United States citizen. In 2009, Jane Doe No. 33 was working
as a model and was invited to Nygard Cay for an audition with the Nygard Companies by Nygard.
At Nygard Cay, Nygard groped and coerced Jane Doe No. 33 to have sex with him and other
women. Nygard told Jane Doe No. 33 that if she did not cooperate, she would not receive a
86. Jane Doe No. 34 is a United States citizen. In approximately 2009, Jane Doe No.
34 was working as a model. Her manager brought her to Nygard Cay for a photo shoot. While
there, Nygard attempted to enter Jane Doe No. 34’s room in the middle of the night to rape or
sexually assault her, but was unable to do so because someone else was in the room.
Approximately one year later, Jane Doe No. 34 attended an event at Nygard Cay with her
boyfriend. While at Nygard Cay, Jane Doe No. 34 went to the bathroom. Nygard entered the
bathroom while Jane Doe No. 34 was urinating and put his hand in her urine stream.
87. Jane Doe No. 35 is a Canadian citizen. In 1986, Jane Doe No. 35 was modeling in
Canada for the Nygard Companies. In 1987, Nygard contacted her by phone and offered her a
paid trip to Nygard Cay. Nygard told her that she would be staying at a guest house located at the
property. When she arrived, Nygard Cay was still under construction and there was no guest
house. Nygard raped Jane Doe No. 35 at Nygard Cay, telling her that she owed him because the
Nygard Companies paid for her travel. Jane Doe No. 35 did not report his crime because Nygard
told her that he regularly played tennis with the chief of police. Nygard’s male assistant drove
Jane Doe No. 35 to the middle of nowhere in the middle of the night and deserted her.
65
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 66 of 270
88. Jane Doe No. 36 is a Canadian citizen. In approximately 1988 or 1989, Jane Doe
No. 36 met Nygard at the airport in the Bahamas and flew on the same flight to Toronto. Several
months later, Nygard invited Jane Doe No. 36 to a concert and she accepted. Afterwards, Nygard
invited Jane Doe No. 36 to have a drink. Nygard took Jane Doe No. 36 to a small living space,
which was located at the Nygard Companies’ office building. While in the room, Nygard raped
Jane Doe No. 36 and then threw $100 in U.S. currency at her. As she was leaving the building,
Jane Doe No. 36 told a security guard employed by the Nygard Companies that Nygard raped her.
The security guard did nothing. Jane Doe No. 36 also spoke to Nygard’s secretary the next day
about the rape. Jane Doe No. 36 eventually reported the rape to police in Toronto.
89. Jane Doe No. 37 is a Canadian citizen. Jane Doe No. 37’s father was in the fur
business and sold Nygard furs, which he used for the Nygard Companies. In approximately 1977,
Jane Doe No. 37 was approximately fourteen or fifteen years old and was waiting in line for the
bathroom at a restaurant in Winnipeg. As Jane Doe No. 37 entered the bathroom, Nygard, who
was waiting behind her in line, pushed his way in and raped her. Jane Doe No. 37 was a virgin at
the time. Approximately a few years later, Jane Doe No. 37 encountered Nygard at a night club
in London. He gave her a drink and Jane Doe No. 37 woke up the next morning naked with Nygard
and another man in a hotel room. When Jane Doe No. 37 was leaving, Nygard pointed his finger
90. Jane Doe No. 38 is a United States citizen. In approximately 1994, Jane Doe No.
38 met Nygard at a party in Los Angeles. Nygard told her that she was beautiful and that she
should model for the Nygard Companies. Nygard had a Nygard Companies’ limo pick Jane Doe
No. 38 up at her residence and take her to his Marina Del Rey property. Nygard took Jane Doe
No. 38 to dinner and a night club. Nygard spiked Jane Doe No. 38’s drink with drugs. On the
66
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 67 of 270
drive home, Jane Doe No. 38 blacked out. She awoke on a bed at the Marina Del Rey property
and Nygard was on top of her raping her. Nygard gave Jane Doe No. 38 $300, but refused to let
her leave until her friend arrived and threatened to call the police.
91. Jane Doe No. 39 is a United States citizen. In approximately 2010-2011, a Nygard
Companies’ employee arranged to have a Nygard Companies’ driver pick Jane Doe No. 39 up and
take her to the Nygard Companies’ New York City headquarters. Jane Doe No. 39 met Nygard
and he invited her to dinner at the W Hotel. Nygard took Jane Doe No. 39 to two adjoining rooms
and instructed her to order food. Nygard then took out a bottle of lubricant and digitally penetrated
Jane Doe No. 39. She managed to flee and escape, even though the door was guarded by security.
92. Jane Doe No. 40 is a Canadian citizen. Jane Doe No. 40 is a former employee of
the Nygard Companies. In approximately 2001, Nygard requested that Jane Doe No. 40 travel to
Nygard Cay, which was paid for by the Nygard Companies. Jane Doe No. 40 was drugged and
sodomized by Nygard at Nygard Cay. The next morning, Nygard threatened Jane Doe No. 40 and
told her if she told anyone what happened, she would “go in the water.”
93. Jane Doe No. 41 is Bahamian citizen who resides in in the United States. Jane Doe
No. 41 is a former employee, to include working as a ComCor employee at Nygard Cay. Jane Doe
No. 41 first attended a “pamper party” as a guest between 2004 - 2006 when she was approximately
eighteen years old. At this first “pamper party,” Jane Doe No. 41 was encouraged to drink heavily
by Nygard’s “girlfriends.” Nygard, along with one of his “girlfriends,” raped Jane Doe No. 41,
while on the Nygard Companies’ boat, the “Lady Hilka.” The next morning, the “girlfriend” paid
Jane Doe No. 41 approximately $500 in United States currency on Nygard’s behalf and the Nygard
Companies’ ComCor employees arranged for a driver to take her home. Jane Doe No. 41
continued to attend “pamper parties” and began working at Nygard Cay as a ComCor employee
67
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 68 of 270
because she needed money. While employed at Nygard Cay, Nygard frequently raped Jane Doe
No. 41 by touching her inappropriately and told her that if she wanted to be paid for her overtime,
or to get a raise in salary, she would have to have sex with him. In 2014, Jane Doe No. 41 travelled
with Nygard to Defendants’ New York City property. Nygard raped Jane Doe No. 41 at his New
York City apartment and forced her to defecate on him. Nygard also coerced Jane Doe No. 41 to
have sex with him and other women in New York City. Nygard took Jane Doe No. 41 to a
“swingers club,” in New York, and was driven there by the Nygard Companies’ driver. Sometime
between 2014-2015, Jane Doe No. 41 was also raped by Nygard at the W Hotel in Fort Lauderdale,
Florida.
94. Jane Doe No. 42 is a Canadian citizen. In approximately 1992, Jane Doe No. 42
was working as a model in Toronto, Canada. Nygard contacted her and told her that Defendants
had a new fashion line coming that he would like her to model. Nygard summoned Jane Doe No.
42 to the Nygard Companies’ Toronto office to model new clothing. Afterwards, Nygard took
Jane Doe No. 42 on a “tour” of the office. Nygard then took Jane Doe No. 42 into a dark room
and shut the door. The room had a large bed in it. Nygard pushed Jane Doe No. 42’s face down
95. Jane Doe No. 43 is a United States citizen. In approximately 2003, Jane Doe No.
43 was invited to Nygard’s Mara Del Rey property by Nygard to sign a contract for a modeling
job. While at Marina Del Rey and shortly after signing the contract, Nygard followed Jane Doe
No. 43 into the bathroom and raped her. Following the rape, Nygard bought Jane Doe No. 43 a
vehicle as payment. Jane Doe No. 43 continued to work for the Nygard Companies as a model
68
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 69 of 270
96. Jane Doe No. 44 is a Canadian citizen. When Jane Doe No. 44 was approximately
fourteen years old, she was living as an adolescent in Winnipeg, Canada. Nygard lured and enticed
Jane Doe No. 44 with false promises of paid trips to California to attend glamorous modeling
parties. On more than one occasion, Nygard took Jane Doe No. 44 in his car to the Nygard
Companies’ property in Winnipeg and had the child perform oral sex on him in his car. Nygard
paid Jane Doe No. 44 after each such occasion with U.S. currency.
97. Jane Doe No. 45 is a United States citizen that resides in the United States. In
approximately 2010, Jane Doe No. 45 was raped, sexually assaulted, and/or sex trafficked by
Nygard on several occasions at his Marina Del Rey property. She was brought to Nygard by a
“madame” under the false pretense of meeting him for modeling opportunities with the Nygard
Companies. Nygard coerced and/or forced Jane Doe No. 45 to engage in commercial sex acts by
falsely promising modeling contracts and acquiescing in threats of violence made to Jane Doe No.
45 and her family by the “madame.” Nygard paid the “madame” with funds from the Nygard
Companies to bring Jane Doe No. 45 to him so that he could rape, sexually assault, and/or sex
traffic her.
98. Jane Doe No. 46 is a United States citizen that resides in the United States. In
approximately 2007, Jane Doe No. 46 was raped, sexually assaulted, and/or sexually battered by
Nygard at the W Hotel in New York City. Jane Doe No. 46 was working as a model and met
Nygard through professional contacts in Hollywood Hills, California. Nygard told Jane Doe No.
46 that she should be a model for the Nygard Companies and offered her a modeling opportunity
in New York City. The Nygard Companies paid for Jane Doe No. 46 to fly to New York City on
Defendants’ “N-Force” jet and booked her a room at the W Hotel. While she was sleeping in her
hotel room, Nygard entered without permission and demanded that Jane Doe No. 46 defecate in
69
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 70 of 270
his mouth. When she refused, Nygard forced Jane Doe No. 46 to perform oral sex on him twice
99. Jane Doe No. 47 is a United States citizen. In the late 1980’s or early 1990’s, Jane
Doe No. 47 was invited to a “pamper party” at Nygard’s home in Marina Del Rey by a modeling
agent. At the “pamper party,” the modeling agent introduced Jane Doe No. 47 to Nygard. Nygard
offered to give Jane Doe No. 47 a tour of his home. Nygard took Jane Doe No. 47 to his room,
100. Jane Doe No. 48 is a United States and Canadian citizen who resides in the United
States. In 1979, when she was seventeen years old, Jane Doe No. 48 met Nygard at a night club
in Winnipeg, Canada. Nygard offered to drive Jane Doe No. 48 home because she needed a ride.
Instead of taking Jane Doe No. 48 home as he promised, Nygard took her to the Nygard
Companies’ Winnipeg office. Nygard raped Jane Doe No. 48 in a lofted area with a bed at the
Winnipeg office.
101. Jane Doe No. 49 is a Canadian citizen who resides in Canada. During the summer
of 1979, Jane Doe No. 49 was fourteen years old and worked for the Nygard Companies. Nygard
provided Jane Doe No. 49 with alcohol on numerous occasions and coerced her to perform oral
sex on him. On one occasion, Nygard digitally penetrated Jane Doe No. 49’s vagina and performed
oral sex on her at a property owned by the Nygard Companies in Winnipeg, Canada.
102. Jane Doe No. 50 is a Canadian citizen who resides in Canada. In 1998, Jane Doe
No. 50 was eighteen years old and was an aspiring model. Nygard asked her to have a business
lunch with him at a restaurant near the Nygard Companies’ office in Montreal, Canada. Nygard
took Jane Doe No. 50 to his penthouse. Nygard sexually assaulted and/or battered Jane Doe No.
50 in the penthouse, forcibly removing her shirt, sucking her nipples, and touching her vaginal
70
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 71 of 270
area. Nygard also threatened both Jane Doe No. 50’s safety and future modeling career when she
103. Jane Doe No. 51 is a United States citizen who resides in the United States. In 2018
and 2019, Jane Doe No. 51 worked as a personal assistant for the Nygard Companies. During her
time working for the Nygard Companies, Nygard forced her to engage in commercial sex acts with
him and sex trafficked her to other men. On one occasion in 2018, Nygard vaginally raped Jane
Doe No. 51 at his penthouse apartment located on the sixth floor of the Nygard Companies’ world
104. Jane Doe No. 52 is a United States citizen who resides in the United States. In
2019, Jane Doe No. 52 attended several “pamper parties” at Defendants’ property in Marina Del
Rey, California. While at one of the “pamper parties,” Nygard lured and enticed Jane Doe No. 52
with false promises of modeling and/or career opportunities with the Nygard Companies and
provided cash payment with Nygard Companies’ funds. Nygard then digitally penetrated her anud
105. Jane Doe No. 53 is a United States and Canadian citizen who resides in the United
States. In approximately 1977, Jane Doe No. 53 met Nygard on an airplane flight from California
to Winnipeg, Canada. Nygard got Jane Doe No. 53’s telephone number and later called her for a
date. Nygard took Jane Doe No. 53 for dinner at a hotel in Winnipeg. Nygard got Jane Doe No.
53 intoxicated and lured her up to his hotel room. While in the hotel room, Nygard made sexual
advances on Jane Doe No. 53 and she told him she did not want to have sex. Nygard forcibly
sodomized Jane Doe No. 53. Jane Doe No. 53 was a virgin prior to the encounter.
106. Jane Doe No. 54 is a United States citizen who resides in the United States. In
January 2010, Jane Doe No. 54 met one of Nygard’s “girlfriends,” Suelyn Medeiros. Knowing
71
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 72 of 270
that Jane Doe No. 54 was a model, Medeiros lured and enticed Jane Doe No. 54 to travel to Nygard
Cay with promises of parties and by telling her that Nygard owned a fashion company. While at
Nygard Cay, Nygard forcibly raped Jane Doe No. 54 on his yacht. In April 2010, Jane Doe No.
54 again traveled to Nygard Cay and Nygard again raped her while on his yacht. On both occasions
the Nygard Companies’ corporate travel department arranged and paid for her flights to Nygard
Cay and Nygard provided Jane Doe No. 54 with cash in U.S. currency from the Nygard
Companies.
107. Jane Doe No. 55 is a United States citizen who resides in the United States. In
approximately 1980, when she was 14-15 years old, Jane Doe No. 55 met Nygard while in
California. Nygard lured and enticed Jane Doe No. 55, who was a run-away, to stay with him at
his home in Playa Del Rey, California. Nygard engaged in sexual intercourse with Jane Doe No.
55, a minor, on numerous occasions. Nygard also sex trafficked and coerced Jane Doe No. 55 to
108. Jane Doe No. 56 is a Canadian citizen who resides in Canada. In 1980, when she
was eighteen years old, Jane Doe No. 56 met Nygard at a night club in Winnipeg, Canada. Jane
Doe No. 56 was taken to the Nygard Companies’ building in Winnipeg. Nygard vaginally raped
Jane Doe No. 56 while at the Nygard Companies’ building. Afterwards, Jane Doe No. 56 fled and
109. Jane Doe No. 57 is a United States citizen who resides in the United States. Jane
Doe No. 57 met Nygard in 2007 when she was twenty-two years old and was working as a model.
Later, in 2009, the Nygard Companies arranged and paid for Jane Doe No. 57 to travel to New
York City to meet him. Jane Doe No. 57 became one of Nygard’s “girlfriends.” In approximately
2010 or 2011, Nygard sex trafficked Jane Doe No. 57 to another man at his apartment in New
72
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 73 of 270
York City. From 2009-2014, Nygard frequently coerced Jane Doe No. 57 to go to “swingers clubs”
with him in New York City. Nygard would often coerce Jane Doe No. 57 to have sex with other
men against her will, while at the “swingers clubs.” Jane Doe No. 57 was paid with cash from the
B. Defendants
110. Defendant Peter J. Nygard is a Finnish and Canadian citizen with permanent
residences in the United States, including in New York City and Los Angeles. He is the founder,
chairman, figurehead, icon, and, directly or indirectly, the 100% owner of the Nygard Companies.
111. Through the Nygard Companies, as Nygard himself alleged in United States federal
court, he “carries on business at various locations around the world as a designer, manufacturer,
distributor, and seller of women’s clothing and accessories. Mr. Nygard and his business are
closely associated in the public eye.”21Nygard regularly travels to the United States, spends
substantial time at his residence in this District, and conducts substantial business in this District
through his global headquarters and flagship store, which are located in this District.22
112. Defendant Nygard Inc. is a Delaware corporation that distributes women’s apparel
113. Nygard Inc. conducts substantial business in this District and at various other
administrative offices in Winnipeg, Canada and its global headquarters in New York City.23
21
See Complaint at ¶¶ 1, 31, Nygard, et al. v. Dipaolo, et al., No. 17-cv-60027 (S.D. Fla. Jan. 5, 2017).
22
See https://vimeo.com/160922029
23
https://corporate.nygard.com/about-nygard/ (“Along with its corporate headquarters located in the heart
of Times Square, the company lays claim to complete design, production and distribution facilities in Los
Angeles, Toronto and Winnipeg, superb research and design studios in New York and Shanghai, and sales
73
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 74 of 270
115. Nygard International conducts substantial business in this District and various other
Bahamas.
117. Nygard uses Nygard Holdings as a depository for funds from Nygard International,
from which Nygard pays for Defendants’ conspiracy and/or illegal sex trafficking venture.
118. Tan Jay International LTD. is a Canadian corporation registered for business in
California, with a registered address at 110 East Ninth St., B1321, Los Angeles, California. Tan
119. There is no corporate distinction between or among the Nygard Companies. At all
times relevant herein, Nygard was the sole owner and executive of the Nygard Companies, their
funds were commingled, and the companies do not observe any corporate formalities.
120. Although Nygard has publicly claimed to have stepped down from the Nygard
Companies, he has not divested his ownership interest in the Nygard Companies, and he continues
to run and direct the Nygard Companies from behind the scenes. A Canadian judge also recently
found that there is no evidence that Nygard has resigned from the Nygard Companies and he still
Nygard, and nothing can happen without his express direction or authorization.
74
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 75 of 270
122. Nygard also regularly invokes the jurisdiction of the United States courts, including
this District, in his personal capacity and through his companies, by regularly filing lawsuits
therein.25
123. The Nygard Companies knowingly conspired, aided and abetted, facilitated, and
directly participated in Nygard’s illegal conspiracy and/or venture by luring young women with
false promises of career opportunities with the companies, paying for and hosting “pamper parties”
under the Nygard brand, withdrawing large sums of cash, paying employees at all such events,
allowing use of the Company-owned “N-Force” jet26 and company finances to transport Nygard’s
victims to destinations in the United States, Canada, the Bahamas and around the world where he
committed his crimes, allowing use of the company-owned boat to transport liquor, drugs, and
supplies for “pamper parties,” and paying for Nygard’s commercial sex acts with his victims,
124. The Nygard Companies also benefit from such activity by using the “pamper
parties,” Nygard’s playboy image, the Nygard flagship store in Times Square, and the Nygard Cay
and Marina Del Rey properties to promote the Nygard brand and products to consumers in the
25
See, e.g. Nygard, et al. v. Bacon, No. 1:19-cv-01559-LGS-KNF (S.D.N.Y. Feb. 19, 2019); Nygard, et
al. v. Dipaolo, et al., No. 17-cv-60027, 2017 WL 4303825 (S.D. Fla. Jan. 5, 2017); Nygard International
Partnership v. Feralio, No. B266683, 2017 WL 4784925 (Cal. Ct. App. Oct. 24, 2017); Nygard v. Jasper,
No. 8:15-cv-1939-T-33EAJ, 2016 WL 9526666 (M.D. Fla. Jan. 4, 2016); Nygard, Inc. v. Uusi-Kerttula,
159 Cal.App.4th 1027 (Cal. Ct. App. 2008); Nygard, Inc. v. Kustannusosakeyhtio Iltalehti, No. B192639,
2007 WL 1775963 (Cal. Ct. App. June 21, 2007).
26
See https://corporate.nygard.com/2005/07/15/ilta-sanomat-fashion-moguls-plane-will-house-a-sauna-
private-movie-theatre-a-disco/.
27
See, e.g., http://www4.nygard.com/SCF/NygardCayBahamas.aspx?ID=38&Folder_id=55
http://www4.nygard.com/scf/News.aspx?id=7826https://www.youtube.com/watch?v=WPFz3_yfj2I;
https://www.youtube.com/watch?v=WUzW-Y0qRB0;
https://www.youtube.com/watch?v=Dx23m_Op0J0; https://www.youtube.com/watch?v=cwRdiTSY_dM
75
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 76 of 270
125. The Nygard Companies paid, promoted, and otherwise rewarded a close ring of
upper-level executives and employees of the Nygard Companies to actively participate in Nygard’s
conspiracy and/or illegal sex trafficking venture, to turn a blind-eye to his sexual abuse, and to
126. Several of Nygard’s victims were also coerced into labor trafficking that directly
benefited the Nygard Companies. Those being labor trafficked were forced to work exceptionally
long hours with little sleep for no additional payment. Often, the jobs they were hired to perform
would be expanded by Nygard to include countless other duties with no additional pay.
127. The TVPRA outlaws sex trafficking activities that affect interstate or foreign
commerce or take place within the territorial jurisdiction of the United States. It is to be construed
broadly because it serves a remedial purpose and uses intentionally broad language.
knowing, or, except where the act constituting the violation of paragraph
(1) is advertising, in reckless disregard of the fact, that means of force,
threats of force, fraud, coercion described in subsection (e)(2), or any
combination of such means will be used to cause the person to engage in a
commercial sex act, or that the person has not attained the age of 18 years
and will be caused to engage in a commercial sex act, shall be punished as
provided in subsection (b).28
28
18 U.S.C. § 1591(a).
76
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 77 of 270
129. As alleged herein, Defendants have knowingly used interstate and foreign
commerce to violate the TVPRA by enticing and recruiting Jane Does Nos. 1-57 and the other
Class members knowing, or in reckless disregard of the fact, that fraud, threats of serious harm,
coercion, and physical force, or knowing that the victim had not attained the age of eighteen years,
130. The TVPRA’s civil provision, 18 U.S.C. § 1596, applies extraterritorially to all
violations that occurred after December 19, 2003, wherein the alleged offender is a national of the
United States; an alien lawfully admitted for permanent residence; or is present in the United
States. The violations against Jane Does Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 19, 28,
32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57 occurred in the Bahamas or Canada after December
19, 2003, and/or occurred within the territorial jurisdiction of the United States, and the Defendants
are lawfully admitted to the United States for permanent residence and/or are present in the United
States.
131. The TVPRA also applies to Nygard’s conduct abroad because the locus of the
Nygard Companies, which supplied resources, including employees and cash payments to the
victims, is in New York City. Further, Nygard has substantial contacts with the United States,
132. The Nygard Companies conspired with Nygard, aided and abetted, facilitated, and
directly participated in Nygard’s conspiracy and/or venture through conduct that originated and/or
133. Nygard uses the Nygard Companies’ money, brand, and resources to facilitate and
commit commercial sex acts in the United States, the Bahamas, Canada, and elsewhere around the
world. The Nygard Companies fund all of Nygard’s “pamper parties” by transferring cash from
77
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 78 of 270
the company’s bank account in Canada and routing it through New York, the Nygard Companies’
worldwide headquarters. All “pamper party” employees and supplies including, without
limitation, food, alcohol, drugs, and entertainment, are paid for from a Nygard Holdings account
that is funded directly by Nygard International. And, critically, the cash that Nygard uses to pay
his victims after raping and/or sexually assaulting them, comes from the Nygard Companies.
134. As explained more fully below, the Nygard Companies also helped Nygard lure
and entice his victims to locations where Nygard can rape, sexually assault, sexually batter, molest,
and/or sex traffic them by offering modeling jobs and other career opportunities with the Nygard
Companies. The rape, sexual assault, sexual battery, molestation, and sex trafficking of many of
Nygard’s victims occurred on company property and was facilitated and enabled by, among others,
135. The Nygard Companies have their global headquarters in New York City and have
actual knowledge of Nygard’s illegal activity through Nygard—the founder, chairman, and 100%
owner of the companies at the time of the acts detailed in this Complaint. Other high-ranking
employees and executives of the Nygard Companies also have actual knowledge of Nygard’s
criminal activity including, without limitation, Vice Chairman, Jim Bennett, Executive Vice
President, Rick Wanzel, Executive Vice President and General Manager, David Paton, Director of
Systems, Greg Fenske, Marketing and Promotions Director, Princy Mathew and Kevin Carkner,
Tiina Tulikorpi, CEO, Sajjad Hudda, President and CEO, Denis LaPointe, and Director of Human
Resources, Wajma Popal. Other finance personnel, including the Nygard Companies’ corporate
accountant, Lili Micic, among others, know or should know about Nygard’s illegal activity,
because they are routinely sending tens of thousands of dollars per month in U.S. currency, without
78
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 79 of 270
136. Nygard has a permanent residence in New York City, which is above his flagship
store on 40th Street and Broadway, near Times Square. The building is leased by Nygard
International.
138. Nygard also owns companies, Nygard NY Retail, LLC, Nygard Partners, LLC, and
139. Nygard enticed and coerced some of his victims, as alleged herein, to engage in
commercial sex acts in, among other places, Los Angeles, Florida and New York City. Jane Does
Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 were raped, sexually assaulted, sexually
battered, molested, and/or sex trafficked in California. Jane Does Nos. 12, 13, 39, 41, 46, 51, and
57 were raped, sexually assaulted, sexually battered, molested, and/or sex trafficked in New York.
140. Nygard uses the Nygard Companies-owned “N-Force” jet to transport his victims
to and from locations in the Bahamas, Canada, New York, California, and Florida, as well as
141. Nygard uses the Nygard Companies-owned boats, some of which are docked in
Florida for months at a time, to transport drugs, liquor, and supplies for “pamper parties.”
142. Nygard also uses the Nygard Companies’ resources, including, without limitation,
the “N-Force” jet and boats, to smuggle women, drugs, liquor, and other supplies into and out of
various jurisdictions including, without limitation, the United States, Canada, and the Bahamas.
143. Nygard uses employees paid by the Nygard Companies, who use Company phones,
computers, email, and social media accounts to entice and lure his victims to locations in the United
States, the Bahamas, and Canada, so that Nygard can rape, sexually assault, sexually batter, molest,
79
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 80 of 270
and/or use fraud and coercion to force them, or, knowing that the victim has not attained the age
of eighteen years, to engage in commercial sex acts. He also keeps a database of potential victims
that is maintained by the corporate IT department on the Nygard Companies’ corporate server.
144. Given these substantial and systematic contacts between the United States and
Nygard’s misconduct in the United States, the Bahamas, Canada, and elsewhere, it is neither
arbitrary nor unfair to exercise application of the TVPRA for Defendants’ activities that partially
145. Application of the TVPRA is also consistent with international law by virtue of the
Palermo Protocols, which are three protocols adopted by the United Nations to supplement the
2000 Convention against transnational organized crime, including the Protocol to Prevent,
violate and/or violated the laws of the States of California and Florida as well as the laws of Canada
and England.
FACTUAL ALLEGATIONS
A. Peter J. Nygard is Synonymous with the Nygard Companies and the Nygard
Companies Have Knowledge of His Sex Crimes.
147. Defendant Peter J. Nygard is a renowned fashion figure and executive in the
women’s apparel industry. He has an estimated net worth of approximately $900 million through
148. Nygard has a permanent residence in the New York City. Nygard’s penthouse
apartment is located on the sixth floor of the Nygard Companies’ World Headquarters in New
29
https://www.youtube.com/watch?v=yH0ODUKH1qE; https://www.youtube.com/watch?v=L1x-Vrn-
33M; https://www.youtube.com/watch?v=iK5hlWl5qLc
80
Case
Case 1:20-cv-01288-ER
1:20-cv-01288-ER Document
Document 48
48 Filed
Filed 06/11/20
06/11/20 Page
Page 81
81 of
of 270
270
photograph
photograph of the “disco
of the "disco room”
room" in Nygard’s penthouse
in Nygard's penthouse apartment
apartment in New York
in New York City:
City:
matchmaker.usa • Follow
JPL V Nygard Capital
71
^ matchmaker.usa © <1? groovy baby
V 0 #Nygard #NYC #nofilter
#purpleandblue #discodanceparty
#penthouse
98w
O Q il P
76 likes
SEPTEMBER 13 2017
Add a comment..,
149.
149. Defendant Nygard
Defendant Delaware corporation that
Nygard Inc. is a Delaware that distributes
distributes women’s
women's apparel
apparel
150.
150. Defendant Nygard
Defendant Nygard International is a Canadian corporation that
that is one of the largest
women’s clothing
women's clothing manufacturers
manufacturers and
and suppliers
suppliers in the world,
in the world, with annual sales exceeding $500
million. Nygard
Nygard International has its administrative offices in Winnipeg,
Winnipeg, Canada and its global
30
https://corporate.nygard.com/about-nygard/
https: //corporate.nygard.com/about-nygard/
81
81
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 82 of 270
Bahamas.
153. Nygard uses Nygard Holdings as a depository for funds from Nygard International,
from which Nygard pays for Defendants’ conspiracy and/or illegal sex trafficking venture.
154. Nygard, Nygard, Inc., and Nygard International have invoked the jurisdiction of the
United States courts by filing lawsuits in the United States courts, including this District, as well
as being “synonymous” with Nygard Inc. and using Nygard Inc. to participate in his conspiracy
and/or criminal venture for both his own benefit and the benefit of the Nygard Companies.31
31
See, e.g. Nygard, et al. v. Bacon, No. 1:19-cv-01559-LGS-KNF (S.D.N.Y. Feb. 19, 2019); Nygard, et
al. v. Dipaolo, et al., No. 17-cv-60027, 2017 WL 4303825 (S.D. Fla. Jan. 5, 2017); Nygard International
Partnership v. Feralio, No. B266683, 2017 WL 4784925 (Cal. Ct. App. Oct. 24, 2017); Nygard v. Jasper,
No. 8:15-cv-1939-T-33EAJ, 2016 WL 9526666 (M.D. Fla. Jan. 4, 2016); Nygard, Inc. v. Uusi-Kerttula,
159 Cal. App. 4th 1027 (Cal. Ct. App. 2008); Nygard, Inc. v. Kustannusosakeyhtio Iltalehti, No.
B192639, 2007 WL 1775963 (Cal. Ct. App. June 21, 2007).
82
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 83 of 270
155. Nygard is the founder, chairman, figurehead, icon, and was, directly or indirectly,
the 100% owner of the Nygard Companies at the time of the events described in this Complaint.32
156. Although Nygard has publicly claimed to step down from the Nygard Companies,
he has not divested his ownership interest in the Nygard Companies, and he continues to run and
direct the Nygard Companies from behind the scenes. Nygard publicly claimed to step down
157. He still controls every aspect of the Nygard Companies’ business, and nothing can
be done without his express authorization or direction. Nygard commingles the Nygard
Companies’ funds, uses the Nygard Companies as his own personal bank account, and does not
158. Nygard admits in public filings that he and his businesses are “closely associated
159. The Nygard Companies’ promotional materials and advertisements also make the
companies synonymous with “one man,” Nygard, who is featured individually on almost all
32
See Complaint at ¶ 1, Nygard, et al. v. Dipaolo, et al., No. 17-cv-60027 (S.D. Fla. Jan. 5, 2017).
33
Id. at ¶¶ 1, 31.
34
See, e.g., video at https://corporate.nygard.com/
83
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 84 of 270
160. In addition, Nygard and his businesses are “closely identified in the public mind,
similar to other fashion houses,” as illustrated by the corporate billboard in the heart of Times
Square.35
161. The Nygard Companies have also trademarked the name “Peter J. Nygard.”
162. The Nygard Companies’ promotional materials prominently feature his Nygard
Cay and Marina Del Rey properties (he even named Nygard Cay after himself and the company).36
The Nygard brand and logo is also featured prominently at Nygard Cay and Marina Del Rey, and
all events hosted at the properties are the Nygard Companies’ corporate functions.37 Nygard has
also stated in public filings that Nygard International has a corporate office at Nygard Cay.
35
See Complaint at ¶ 31, Nygard, et al. v. Dipaolo, et al., No. 17-cv-60027 (S.D. Fla. Jan. 5, 2017).
36
See https://www.youtube.com/watch?v=GQRDS-KlOw0; https://vimeo.com/160922029
37
See
http://pimpingpictures.com/Jarmopohjaniemi.com/Blog/Entries/2008/6/11_Nygard_Cay_Hosts_Playboy_
Shoot.html
84
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 85 of 270
163. Nygard and the Nygard Companies also use the Nygard Cay property to promote
the Nygard Companies’ brand by renting it out and having events and parties with celebrities and
politicians including, among others, Oprah Winfrey, George H.W. Bush, Robert De Niro, and Sean
Connery.38
164. Nygard uses the Nygard Cay and Marina Del Rey properties, his customized “N-
Force” jet, his boat, and his New York City apartment above his flagship store—each of which is
owned or leased by the Nygard Companies or companies affiliated with the Nygard Companies—
to promote himself and the Nygard Companies and, at the same time, facilitate the commission of
38
See https://www.lawcrossing.com/article/3372/Indulge-in-the-Pleasures-of-Nygard-Cay/; see also
https://corporate.nygard.com/2006/12/09/nygards-cay-an-island-of-fantasy-the-ultimate-treehouse/
85
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 86 of 270
165. Nygard hosts “pamper parties”39 at his Nygard Cay and Marina Del Rey properties,
under the Nygard brand, as a means to further Defendants’ illegal conspiracy and/or venture and
also benefit the brand of the Nygard Companies.40 The “pamper parties” and all supplies—
including alcohol and drugs provided to minors—are paid for by the Nygard Companies.
166. Employees that staff the “pamper parties” are also paid by the Nygard Companies
167. In addition to staffing the parties with bartenders, cooks, servers, maids, and other
employees, the Nygard Companies also employ people to work at what Nygard refers to as
ComCor, who are used in California and the Bahamas to ensure that potential victims attend the
39
See https://www.youtube.com/watch?v=WPFz3_yfj2I
40
See
http://pimpingpictures.com/Jarmopohjaniemi.com/Blog/Entries/2008/6/11_Nygard_Cay_Hosts_Playboy_
Shoot.html
86
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 87 of 270
168. The Nygard Companies’ ComCor employees also recruit and/or procure potential
victims for Nygard. ComCor employees are paid by the Nygard Companies.
169. When girls were flown to the Bahamas on the Nygard Companies’ “N-Force” jet
for “pamper parties,” the passengers’ passports were often collected, their return flight was
cancelled by the corporate travel agency personnel, and approval from Nygard was required to
leave Nygard Cay and the island. Nygard expected a sex act before he was willing to consider
170. Similarly, once Nygard’s victims arrive at Nygard’s Marina Del Rey property for
“pamper parties,” they are not permitted to leave without Nygard’s express permission. The
property is gated and all doors are equipped with keypads that require a key code, known only by
Nygard, to open. Nygard demanded his victims engage in sex acts before allowing them to leave.
171. Once Nygard selects his victims, his employees are sometimes instructed to drug
the victims, by placing Rohypnol and/or other mind-altering drugs in their drinks (referred to as
172. Nygard uses the “pamper parties” to both promote the Nygard Companies’ brand
and to facilitate rape, sexual assault, sexual battery, molestation, and/or sex trafficking. He is
acting on behalf of the Nygard Companies, under the brand and reputation of the companies, and
173. That Nygard is a sexual predator is an open secret at the Nygard Companies. Over
the course of decades, executives, officers, and directors of the Nygard Companies as well as the
corporate HR Department were instructed by Nygard to pay off anyone who accused Nygard of
sexual misconduct and force them to sign nondisclosure agreements. These upper-level
executives, officers, directors, and employees helped Nygard cover up his crimes and continued
87
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 88 of 270
to facilitate and enable his crimes so that they would receive financial benefits and career
advancement.
174. These upper-level executives, officers, and directors knew or should have known,
through the exercise of reasonable diligence, of Nygard’s use of company funds and resources to
engage in and cover-up sexual misconduct. Yet, they negligently and/or recklessly did nothing to
stop him, in violation of their fiduciary duties to the Nygard Companies, Nygard Companies’
175. In 1980, Nygard was arrested for rape, but the charges were later dropped when the
woman accusing him decided not to testify against him. Nygard used funds from the Nygard
Companies to pay the woman off so that she would not testify against him.
176. Over the course of decades, scores of female employees of the Nygard Companies
have also accused him of sexual improprieties. These stories share striking similarities and are
well known throughout the Nygard Companies. Several examples are set forth below.
177. One woman was hired as a merchandiser for the Nygard Companies. She reported
to the corporate HR department that Nygard entered her hotel room, while they were on a corporate
business trip, and raped her. A few hours after she reported the incident to the Nygard Companies’
HR Department, a company executive arrived at her door with a check for $8,000 and a non-
178. In 1995, another former female employee sued Nygard for having sex with her
“against her will.” Nygard and the Nygard Companies reached an undisclosed settlement with the
179. Another female employee reported that she was forced to stand next to Nygard at a
meeting with company executives present. During the course of the meeting, Nygard rubbed his
88
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 89 of 270
foot up and down the woman’s thigh while the Nygard Companies’ executives watched. Many
180. In 1996, the Winnipeg Free Press wrote a front-page story detailing Nygard’s
sexual misconduct and relating to interviews with seven former and current female employees of
the Nygard Companies. Three female employees filed sexual harassment complaints with the
Manitoba Human Rights Commission against Nygard and the Nygard Companies. In that year
alone, the Nygard Companies paid out $20,000 in settlement over sexual assault claims by female
181. The Nygard Companies’ former communications manager reported that she would
walk into meetings with Nygard and his pants would be down frequently and he would be fondling
himself. On one occasion, she reported that she was instructed to open a closet door to get
something and she found a box full of pornographic photos of Nygard with various women. She
reported Nygard’s conduct to the Human Rights Commission and she received a $6,000 payoff
182. The same employee was responsible for hiring a woman that became Nygard’s next
target. Nygard regularly made sexual advancements towards her at work in front of other
employees and executives of the Nygard Companies. She reported Nygard’s conduct to the
Human Rights Commission and the Nygard Companies paid her $8,000.
183. Another female employee of the Nygard Companies reported that she had walked
into Nygard’s office and he was stroking his genitals at his desk. When the woman turned away,
Nygard dropped his pants and began masturbating while looking at her. She reported Nygard’s
conduct to the Manitoba Human Rights Commission and the Nygard Companies paid her $4,500.
89
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 90 of 270
184. Former employees of the Nygard Companies have also stated that Nygard equips
the Nygard Companies offices in Winnipeg, Toronto, and Marina Del Rey with hidden rooms that
he uses as “sex dens.” The existence of these rooms is common knowledge among employees of
185. Rather than helping to create a professional work environment for female
employees, the Nygard Companies’ HR department, functioned to cover-up his rapes, sexual
assaults, and molestations of company employees and other woman who were brought to the
corporate offices under false pretenses of modeling and other career opportunities. The corporate
HR Department regularly paid off Nygard’s accusers and forced them to sign non-disclosure
agreements so that Nygard could continue his pattern and practice detailed below.
B. Nygard is Able to Engage in A Uniform Pattern and Practice of Sex Trafficking Due,
in Part, to His Intimidation and Corruption Tactics.
186. In 2007, the Bahamas had the highest rate of reported rapes in the world, and, in
2016, it had the highest incidence of rape per capita in the Caribbean. The UN Woman narrative
on gender-based violence in the Caribbean found that the worldwide average for rape was fifteen
per 100,000, while the Bahamas has an average of 133 per 100,000.41
41
http://www.unodc.org/pdf/research/Cr_and_Vio_Car_E.pdf;
http://www.tribune242.com/news/2016/feb/16/bahamas-has-worst-total-region-rapes/.
90
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 91 of 270
187. Global estimates are that between 60 and 95 percent of sexual crimes go unreported
and that even those reported are unlikely to be prosecuted. Rape, in particular, is the most
stigmatization, victim shaming, government corruption, and weakly-enforced laws. For example,
in 2013, the Bahamas Crisis Centre in New Providence alone counselled 122 new clients for rape
and 42 for sexual assault, while, during that same period, the police recorded only 104 rapes for
the entire country. During the same time period, data from Princess Margaret Hospital’s
emergency room alone shows it treated nearly 1.5 times the amount of country-wide rapes reported
to the police.43
189. In 2018, only 55 rapes were reported in the Bahamas, while Cleveland, Ohio, which
190. The local word for rape in the Bahamas is “hush.” It is not discussed or spoken of
as a societal problem.
191. In 2018, the State Department issued a travel advisory warning that “sexual assault
42
Heather Sutton, IDB Series on Crime and Violence in the Caribbean: Crime and Violence in the
Bahamas, June 2016, at 34-25, available at https://publications.iadb.org/en/publication/12508/crime-and-
violence-bahamas-idb-series-crime-and-violence-caribbean.
43
Id.; https://ewnews.com/711-rapes-presented-to-hospitals-since-july-2013
44
https://www.nytimes.com/2020/02/22/world/americas/peter-nygard-louis-
bacon.html?referringSource=articleShare
91
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 92 of 270
192. Rapes in the Bahamas also have very low police-clearance rates. On average, the
percentage of rape cases solved between 2010 and 2013 was 40 percent. This means that rapes
are highly unlikely to be prosecuted, which does little to stimulate better reporting.45
193. Another reason why sex crimes are so widely under-investigated and prosecuted in
the Bahamas is because violence against women and girls is often seen as a private matter, in which
the State should not interfere. A culture of acceptance interrelated with strong patriarchal gender
194. Due, in part, to these factors, scores of Nygard rapes and sexual assaults in the
society.”47 The government has laws to combat corruption of and by public officials, but they are
inconsistently applied.48
196. According to one survey, despite one in ten Bahamians disclosing that they had
been forced to pay a bribe within the past year to obtain public services, few reported the corruption
to law enforcement. According to the survey, almost half were too scared of the consequences—
such as potential retaliation and victimization—to report allegations of bribery by public officials.
45
Id.
46
Human Rights Council, Report of the Special Rapporteur on violence against women, its causes and
consequences, on her mission to the Bahamas, at 4 (May 25, 2018), available at
https://undocs.org/en/A/HRC/38/47/Add.2.
47
http://www.tribune242.com/news/2018/apr/26/not-a-single-bribe-demand-is-probed/
48
https://www.globalsecurity.org/military/world/caribbean/bs-corruption.htm
92
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 93 of 270
Fear is a major obstacle to stamping out a problem that the Bahamian Prime Minister recently
estimated costs the Bahamian economy approximately $200 million per year.49
197. For this reason, few people in the Bahamas (approximately 6%) actually report
corruption when they experience it. Overwhelmingly, the survey showed that of those who
reported an incident of corruption to the authorities—not one respondent stated that the authorities
took action against the government officials involved. This is despite the evidence showing that
one in eight Bahamians (approximately 13%) who had contact with the police in the year prior to
October 2017 had paid a bribe in order to get services they needed.50
198. Bribery in the courts was also reported, with one in ten people who came into
contact with the courts having paid a bribe in the previous twelve months, demonstrating that there
is still an acute corruption risk in this key law and order institution (10%). The findings indicate
how corruption is undermining the rule of law and public safety in the Bahamas, in addition to the
Bahamians’ inability to police its borders and determine who can reside in the country.51
Corruption has become “a cultural element of the mindset of Bahamians[,]” and “[i]t’s rooted in
199. Additionally, the Royal Bahamas Police Force scored an unwanted first by
becoming the first police organization in the Caribbean to rank top for both receiving bribery
payments and being perceived as the country’s most corrupt public institution. As a result,
49
http://www.tribune242.com/news/2018/apr/26/not-a-single-bribe-demand-is-probed/
50
Id.
51
Id.
52
Id.
93
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 94 of 270
Bahamians are unwilling to report corruption and other crimes to law enforcement because they
200. Nygard routinely hired Bahamian policemen for “personal security,” which
furthered his victims’ mistrust of the police. Below is a photo of Bahamian policemen at Nygard
Cay.
201. Due to the low police clearance rates for investigations of sexual crimes and the
cultural attitude toward sexual crimes and the victims of such crimes, victims of sexual crimes in
the Bahamas rarely pursue their claims. They are ashamed and embarrassed, fear retaliation and
victimization, rightfully do not trust law enforcement to pursue and prosecute their attackers, and
53
Id.
94
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 95 of 270
3. Nygard has Significant Power and Influence in the Bahamas, Resulting from
His Widespread Bribery and Bahamian Political Contributions.
202. During the time-period relevant to this action, Nygard was well known in the
Bahamas as one of the wealthiest and most influential individuals with a home there.54 He has
also spent significant money, provided by the Nygard Companies, to bribe Bahamian officials
including, without limitation, law enforcement, and to gain political influence and power on the
203. Nygard’s political connections in the Bahamas go as far back as the 1980s when he
paid government officials to provide him with the property where he built his Nygard Cay estate.
In the early 1990s, Nygard paid members of the Progressive Liberal Party (“PLP”) for help relating
to his Nygard Cay property and expansion plans. In 1992, Nygard wrote to then minister of
agriculture, Perry Christie (“Christie”), regarding a “significant” pledge he had made, asking for
help relating to the expansion of his property, and stating “this whole world is based on one hand
helping the other and you know that I am prepared to do whatever is in my capacity to help out the
Bahamas and the PLP party and of course yourself in an way I can.”
204. Nygard’s long relationship with the PLP and its leader, Christie, continued for
decades. Christie eventually became the Prime Minister of the Bahamas from 2002-2007. The
PLP and Christie, however, lost the 2008 election to the rival political party, the Free National
Movement (“FNM”).
54
See, e.g., https://www.youtube.com/watch?v=n6KOtR4G37U;
https://www.youtube.com/watch?v=d55fJKf8zsA
55
See, e.g., https://www.youtube.com/watch?v=zKFjnnHXDGs;
https://www.youtube.com/watch?v=ih55gjHvEp8
95
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 96 of 270
205. Nygard made significant financial contributions, using the Nygard Companies’
funds, and efforts in order to help the PLP and Christie regain power in the Bahamas by winning
206. Nygard contributed at least $10 million (in U.S. or Bahamian currency) to get
Christie elected and paid to have individuals spread bad press about the FNM. He also paid $300
to each person who would vote for the PLP in the 2012 election. Nygard was thus able to
successfully help Christie get elected for a second term (2012-2017), in exchange for political
207. Nygard and Christie were in regular contact with one another before, during, and
after the 2012 election.57 Nygard regularly invited political figures, such as Bahamian Parliament
members including, without limitation, Shane Gibson, Dion Foulkes, and police officers such as
Royal Bahamas Police Superintendents Allan Emmanuel, Stephen Dean, and Wendall Deveaux,
to attend his “pamper parties.” As stated by the Nygard ComCor department, which answers
exclusively to Nygard, the photograph below describes “Mr. S. Gibson” as attending and pictured
56
See http://www.tribune242.com/news/2013/jul/18/mp-concerns-nygard-donated-5m-plp/;
http://www.tribune242.com/news/2013/jul/23/nygard-admits-backing-plp-sworn-affidavit/
57
See, e.g., http://www.tribune242.com/news/2017/may/05/fresh-questions-over-las-vegas-trip-pm-
gibson-and-/
96
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 97 of 270
208. Nygard provided PLP party members, including Shane Gibson and corrupt police
officers, with children and young women to engage in commercial sex acts with in exchange for
favors for Nygard. Nygard also provided some of his “girlfriends” to Bahamian politicians and
police officers for sexual gratification. Nygard did so to gain influence with these politicians and
law enforcement officials, as well as to gain compromising information about them in order to
209. For Example, former Playboy Playmate, Anna Nicole Smith, was a “girlfriend” of
Nygard from approximately 1999-2002.58 Nygard “gifted” Anna Nicole Smith to Shane Gibson,
58
See https://www.whosdatedwho.com/dating/peter-nygard-and-anna-nicole-smith.
97
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 98 of 270
who later resigned from his position as Immigration Minister after photographs surfaced of him in
210. On another such occasion, one of Nygard’s “girlfriends,” Jane Doe No. 12, was
sent by Nygard to Perry Christie’s office to “ask for help” with a personal matter. When she
arrived, Christie had “sexy” photos of her, that she had taken for Nygard, spread across his desk.
Christie took his penis out and attempted to engage in sexual activity with Jane Doe No. 12. Jane
Doe No. 12 refused. Afterwards, Nygard asked about Jane Doe No. 12’s encounter with Christie
and became upset when he learned that Jane Doe No. 12 did not have sexual intercourse with
Christie.
211. On September 5, 2012, shortly after the 2012 election, Prime Minister Christie and
59
See https://www.kltv.com/story/6107637/bahamas-official-resigns-over-photos-with-anna-nicole-smith/
98
Case
Case 1:20-cv-01288-ER
1:20-cv-01288-ER Document
Document 48
48 Filed
Filed 06/11/20
06/11/20 Page
Page 99
99 of
of 270
270
Peter
Nygard
Nygard
k l Perry
Perry
Christie
CH
'
, /'
celebrate the
the PLP election victory in 2012, including the
the following, without
without limitation: the
limitation: the
Michael Darville;
Michael Darville; the Minister
Minister of Education,
Education, Jerome Fitzgerald;
Fitzgerald; the
the Minister of Agriculture, Alfred
Gray; the
the Minister
Minister of Housing & Environment, Ken Dorsett; the Minister
Minister of Health,
Health, Dr. Perry
>- h
!E
JJ o L
.V
9 Q ilj
69 likes
n
3
60
60
See https://www.youtube.com/watch?v=Pw1xUXQNelg;
https://www.youtube.com/watch?v=Pw1xUXQNelg; see
see also
https://www.yotube.com/watch?v=jVfw9LOSOZo
https: //www .yotube.com/watch?v=j Vfw9LOSOZo
99
99
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 100 of 270
213. Bahamian Parliament member and PLP member, Shane Gibson, was paid
approximately $94,131.10 prior to the general election in 2012 and into 2013. The funds were
deposited directly to his bank account in the United States, and the payments were made with funds
from the Nygard Companies. Shane Gibson could not explain why the funds were deposited in an
offshore U.S. bank account, as opposed to his bank accounts in the Bahamas.61
214. Eric Gibson, who is Shane Gibson’s brother, was also on Nygard’s “payroll” and
was paid directly by the Nygard Companies, acting as a conduit to covertly funnel money between
Nygard and the PLP. Nygard instructed his ComCor employees to have a check ready for Eric
Gibson every week, even though he did not appear to provide any work for Nygard. Pat Smith, a
PLP loyalist with close connections to Perry Christie also acted as a conduit to covertly funnel
money to the PLP and was provided with regular payments from the Nygard Companies “per PJN”
(Peter J. Nygard).
61
http://www.tribune242.com/news/2017/apr/24/nygard-gave-gibson-94000-5000-month-paid-ministers/
100
Case
Case 1:20-cv-01288-ER
1:20-cv-01288-ER Document
Document 48
48 Filed
Filed 06/11/20
06/11/20 Page
Page 101
101 of
of 270
270
11094
Nl TO
mmmrnm
tui) C>(oO^^0 \ ^
I (^C -Csi%5s9-rJ
S&j&J s Gfooo^
Mill
^ R«'VJ| IVrMtk
L] UtCiMiwta IYGAHO
-J *>»WNi linlfr
'i
'«». f*..E, n«kiinj> /
a*?
5"|
W ~ _ «W9i1 1 I
I" cntjh-
IC •axo"
. • 5ood"* I 14,000"
CP - jjf| ® 3 IZ5 L
fXJSE_
5S8JjLui
ocounrv «Ut«l*-00tt IBM **»»
v^.
u oWltOM'
- "7 rgOIIOkK'
(5000 00
•Ot«lini042 •p#d.W22fi»11
(1900000
"Pild "02/03/301 1 I r 11024 VMd "07/04/2011
"ON* #10074
1 ~
E
1 . . Ca » 15, coo"*
rt
JL
_ 0»04A.O| |
• COO
£fic f?14soM s J'OO-oO
I "frrifrtrW
5ESF
r^crr
SSrtE.
^ito>.K <o 1 1*1-00*: IBO »»l moiiiki' «»»i IM WOHIH*
HOUSINGS I imitco w
11094
4
*
t ' fet ^™jL • nsct>-
. • Sao"
i
r&US^A J
S~
* CeOOO*^
IK. Hunt* am<
0 'w~
rttMl* 43IUMOM
0
,IWV
KJ ^
E vr Cu» • -sap-
f
Mr. KujJluJ
0
l_3?
IM >IM»
"Choc* #110)7 IM
101
101
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 102 of 270
215. Nygard was also close with Deputy Prime Minister Phillip “Brave” Davis (“Davis”)
and regularly met with him at Viking Hill and paid bribes to him and his political aides. Nygard
met Davis through one of his former “girlfriends” who also was a former girlfriend of Davis.
216. Davis allegedly introduced Nygard to known Bahamian gangsters and convicted
criminals, Livingston “Toogie” Bullard and Wisler “Bobo” Davilma.62 Nygard paid “Toogie” and
“Bobo” with funds from the Nygard Companies to intimidate anyone who spoke out against him
or his initiatives by, among other means, directing them to firebomb his detractors’ vehicles and/or
businesses, instructing them to threaten to kill those who oppose him, and commit other acts of
217. Covert recordings have captured Nygard discussing illicit activity with Toogie and
Bobo including, among other things, committing acts of violence against others and setting up
218. Nygard used his political connections and bribes to successfully gain building
permits and to receive other favorable treatment including, without limitation, overlooking his
illegal activities.
219. In the months leading up to the general election of May 2012, many politicians
visited Nygard Cay to receive cash for their campaigns. Jane Doe No. 41 personally handed these
62
See
https://www.bahamaslocal.com/newsitem/147536/Court_documents_claim_Deputy_PM_sent_criminals_
to_protect_Nygards_interests.html; https://www.youtube.com/watch?v=xCa9LEJsg2I (Nygard berating
his security guard, Leo Thurston).
63
See http://www.tribune242.com/news/2016/mar/10/claim-nygard-hired-hitmen/
64
See https://www.youtube.com/watch?v=qN4Xwu5hpAw&feature=youtu.be
https://www.youtube.com/watch?v=0_LrErjvyaQ&feature=youtu.be
102
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 103 of 270
politicians cash from the Nygard Companies. Nygard’s strategy was to fund the government so
220. Nygard had Bahamian police officers on his “payroll” and they frequently visited
Nygard Cay, including Royal Bahamas Police Chief Superintendent, Solomon Cash,
Superintendents Allan Emmanuel, Stephen Dean, and Wendall Deveaux, and Royal Bahamas
Police officer, Camela McCoy. He used them to help “bury” reports of sexual abuse, supply
information regarding ongoing investigations into his sex crimes, trace the whereabouts of people
who crossed him, and intimidate, threaten to arrest, and otherwise harass his victims to ensure that
they would not come forward. Nygard often alludes to the fact, in front of his “girlfriends,” that
he is powerful enough in the Bahamas to have people killed without being investigated.
221. Indeed, when Nygard learned of the investigation of his illegal conspiracy and/or
sex trafficking venture, he engaged lawyers to facilitate bribery payments to top Bahamian police
officials to get more information that would enable him to attempt to bribe victims or intimidate
222. Nygard also regularly bribes Bahamian officials with U.S. currency from the
Nygard Companies to prevent customs from searching his plane, prevent customs from checking
the passports of the young women onboard, and to prevent customs from inspecting the
passengers’ luggage. This allows Nygard to traffic his victims to and from the Bahamas, transport
drugs intended for his victims, and transport other supplies for “pamper parties” in the Nygard
223. Nygard does the same with the Nygard Companies’ boats and regularly transports
supplies and victims for his “pamper parties” from Florida to the Bahamas.
103
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 104 of 270
224. In addition to politicians, government officials, and police, Nygard also paid for
favorable media coverage and propaganda in the Bahamas to help further his agenda, silence his
victims, and perpetuate Defendants’ conspiracy and/or sex trafficking scheme. Prominent
Bahamian media personalities, such as Phillipa “Lady” Russell, Carlos Mackie, Wendall Jones,65
Sherman Brown,66 Carvel Francis, and Steve McKinney, were frequent visitors to Nygard Cay and
were on Nygard’s payroll to obfuscate, smear, deflect and distort the truth.
225. Nygard’s Bahamian victims have been previously unable to come forward to report
his illegal activity and pursue their claims against him for several reasons including, without
limitation, cultural stigmatization, shame, weak laws that are rarely enforced, low clearance rates
for sexual-assault investigations, corrupt law enforcement and government officials, fear of
Nygard’s wealth, power, and influence in the Bahamas, and psychological manipulation and
intimidation tactics used by Nygard, including the commonly held belief that Nygard has bribed
4. Nygard Also Has Considerable Influence in the United States, Canada, and
Elsewhere.
226. In addition to Nygard’s political power in the Bahamas, Nygard and the Nygard
Companies also boast of his “extensive political leverage” in the United States and Canada, and
tout his relationships with “many high profile dignitaries” including “Governor General Ray
Hnatyshyn, Prime Minister Brian Mulroney, Prime Minister Jean Chrétien, President Gorbachev
of the USSR, President Mauno Koivisto of Finland, Sha Lin – Mayor of Shanghai, President
Vicente Fox of Mexico, President George Bush Sr., & Prime Minister Pindling of the Bahamas.”67
65
http://www.tribune242.com/news/2018/oct/11/journals-publisher-smear-campaign/
66
http://www.tribune242.com/news/2015/dec/24/sherman-brown-faces-prison-after-being-found-guilt/
67
https://web.archive.org/web/20160313072707/http://corporate.nygard.com/larger-than-life/
104
Case
Case 1:20-cv-01288-ER
1:20-cv-01288-ER Document
Document 48
48 Filed
Filed 06/11/20
06/11/20 Page
Page 105
105 of
of 270
270
with aa jacket
with jacket with the President’s
with the President's seal
seal on
on it.
it.
\y
7 -J A w
6 s.'
0 V
SH ION
by politicians in Winnipeg
by well as “received
Winnipeg and Toronto as well "received the
the prestigious
prestigious Queen Elizabeth II
Queen Elizabeth II
Golden
Golden Jubilee
Jubilee medal
medal for
for helping to ‘create
helping to 'create the
the Canada
Canada of today, and
of today, to recognize
and to Mr. Nygard
recognize Mr. Nygard for
cME
I f
i. £Q /
ft toft
P;i
\
] m
s
' I
68
Id.
Id.
105
105
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 106 of 270
229. Nygard was also given the key to the City of Winnipeg and had considerable
230. Nygard’s wealth, political connections, and power and influence in the Bahamas,
Canada, and the United States helped perpetuate Defendants’ conspiracy and/or sex trafficking
venture by preventing the victims, Defendants’ employees, and other witnesses from reporting his
illegal conduct.
231. Nygard engages in a continuing conspiracy and uniform pattern and practice to
rape, sexually assault, sexually batter, molest, and recruit, lure, and entice children and women,
knowing, or in reckless disregard of the fact, that means of force, fraud, and coercion, or that the
child had not yet attained the age of eighteen years, to cause the victims to engage in a commercial
sex act. Methods employed by Nygard to commit sex trafficking include, but are not limited to,
the use of physical force, threatening physical force, drugging victims, kidnapping, promising
confiscating his victim’s passports, and preventing exit from the Nygard Cay, Marina Del Rey,
232. Nygard has targeted, and instructed his employees and associates to target, children
and young women. He has frequently stated “the younger, the better.” Nygard primarily preys on
young, vulnerable, and impoverished Bahamian girls because he knows that they will not report
69
https://www.winnipegfreepress.com/local/moguls-key-to-the-city-could-be-rescinded-568266372.html
106
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 107 of 270
his crimes to law enforcement, particularly in a climate where it is well known that Nygard bribes
233. Nygard also routinely targeted young aspiring models from the United States,
Canada, and elsewhere. He uses the Nygard Companies’ brand, his influence and power in the
fashion industry, and false promises of modeling and other career opportunities with the Nygard
Companies to lure them to his properties in, among other places, Marina Del Rey, New York City,
Winnipeg, and Toronto to rape, sexually assault, sexually batter, molest, and sex traffic them.
234. Among other deviant acts, Nygard often sodomizes his victims and demands that
they defecate on him, including in his mouth. He also requests that his victims urinate on him and
demands that victims on their menstrual periods provide him their menstrual blood for
consumption.
235. Nygard often exposes his victims to pornography as part of his sexual pattern.
Victims have described seeing every type of sexual act, to include but not limited to, pornography
236. Due to the extreme deviant nature of Nygard’s sexual conduct, his victims feel even
more degraded, ashamed, and embarrassed than the typical sexual assault victim.
1. Nygard Uses His Nygard Cay and Marina Del Rey Properties to Further the
Nygard Brand and Facilitate His Illegal Conduct.
237. In 1987, Nygard built a 150,000 square-foot compound on Lyford Cay in the
Bahamas, which became known as “Nygard Cay.” Nygard uses the property to host company
“pamper parties” to promote the Nygard brand and facilitate his sex trafficking. Nygard Cay is
registered in the name of Peter Nygard and is used to promote the Nygard Companies’ brand and
all construction or maintenance that occurs on the property is paid for by the Nygard Companies.
107
Case
Case 1:20-cv-01288-ER
1:20-cv-01288-ER Document
Document 48
48 Filed
Filed 06/11/20
06/11/20 Page
Page 108
108 of
of 270
270
Cay, there
there is a large security gate stationed with security personnel. Only those
those with permission
239.
239. Once entrance to
to Lyford
Lyford Cay is granted, there
there is an additional fortress-like gate
IU7- .
H
,
•» - Vr S ,,
,
' '51*
y.-jfe&S W
'..•••J
V
|,1| m
V , IB , , | .1 ! I I ( JJij
!
M, tr.
i\ y >;• - ^ - • - Ol it swMWfflmmI
<-11 11 1 i« I " i ? I. 1 J !"
v '• a, :
> I
I
t
7
• ' . .<•>
MSV tlLdl^S 1; e U
'M
^pii \
r"X
-VJ
N7 > >
/' • I
W< * 1
'L
•l\^
1
B
ci
7 "
Uu
S°t'C£
?-
3
“pamper
"pamper party”
party" guests
guests who enter Nygard that they must “register”
Nygard Cay is that with ComCor by
"register" with
completing a form requesting personal information and taking a headshot and a full-body shot,
which is then
which then added to the
the ComCor database.
without Nygard's
without Nygard’s express
express permission.
permission. The security gate staff will not open the
the gate, unless
unless they
108
108
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 109 of 270
are instructed to do so by Nygard himself. The walls of Nygard Cay are tall, equipped with barbed
wire, and surround the entire property. The only way out, other than the main gate, is to swim
242. Nygard also has a permanent residence and office of the Nygard Companies located
in Marina Del Rey, California. Similar to his Nygard Cay property, the Marina Del Rey property
is gated with security and no one can leave without Nygard’s express permission.
243. Upon entrance to the Marina Del Rey property, all of Nygard’s guests are similarly
registered with the Nygard Companies’ ComCor employees. They are required to provide their
personal information, a full body shot, and head shot. This information is then saved to the a
ComCor database that is located on the same server as the database used at Nygard Cay.
2. Nygard Hosts Company “Pamper Parties” to Further the Nygard Brand and
Facilitate His Illegal Conduct.
244. Nygard uses fraud and deceit to knowingly recruit, lure, and entice children and
women to his Nygard Cay and Marina Del Rey properties under the false pretense of attending
weekly company modeling events known as “pamper parties” and promising, among other things,
109
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 110 of 270
interviews for lucrative modeling opportunities when, in fact, he has no intention of fulfilling his
empty promises.
245. “Pamper parties” are held out by Nygard and the Nygard Companies as modeling
246. On the surface, young girls and women are invited to enjoy the amenities of the
Nygard Cay and Marina Del Rey properties and are pampered for the day with free photo shoots,
manicures, pedicures, and massages. These parties are intended, in part, to promote the Nygard
brand and its products. They are promoted on the Nygard Companies’ website and through
corporate social media accounts. Females from the United States, Canada, the Bahamas, Jamaica,
247. Nygard also uses these “pamper parties” to facilitate and further his conspiracy
and/or sex-trafficking venture. The atmosphere at the “pamper parties” is intended to impress
vulnerable and impoverished children and young women, so that he can lure and entice his victims
onto the Nygard Cay and Marina Del Rey properties with promises of modeling contracts and
other opportunities to rape, sexually assault, sexually batter, molest, and/or coerce, defraud or force
them, or knowing that they had not attained the age of eighteen years, to engage in commercial
sex acts.
248. Nygard regularly hosted “pamper parties” at the Nygard Cay and Marina Del Rey
properties on Sundays when he was in each location with the hidden purpose of facilitating his
crimes.
249. In addition to massages, manicures and pedicures, gourmet food, and jet skis,
“pamper party” attendees are encouraged to drink excessive amounts of alcohol (intentionally
110
Case
Case 1:20-cv-01288-ER
1:20-cv-01288-ER Document
Document 48
48 Filed
Filed 06/11/20
06/11/20 Page
Page 111
111 of
of 270
270
made
made extra
extra strong,
strong, per Nygard’s instructions)—and
per Nygard's instructions)—and are sometimes unknowingly drugged—so that
that
they are
they are “loose”
"loose" for Nygard to
for Nygard to sexually
sexually prey
prey on them.
on them.
I 1
1
fi
^6§
* >
'j5m
Pi IO-
i i.-.y-. ,.
250.
250. the “pamper
Generally, only females are permitted to attend the "pamper parties,”
parties," and all
ComCor follow:
111
111
Case
Case 1:20-cv-01288-ER
1:20-cv-01288-ER Document
Document 48
48 Filed
Filed 06/11/20
06/11/20 Page
Page 112
112 of
of 270
270
Bahamas ComCor
Yea u tan bnng ae many guests as u Ike as long as tbey are your size or smaller and tney have to
be female
Bahamas ComCor
Bahamas ComCor
no men are allowed unless they come in a car with 5 females sexy females :-)
“pamper
"pamper parties.”
parties." Only females that
that meet Nygard’ss sexual specifications of being
meet Nygard' being slim bodied and
face
face and
and nice toilet.” Other girls that
nice toilet." that do not meet this
this qualification are turned
turned away at the security
gate.
gate.
Bahamas ComCor
Bahamas ComCor
112
112
Case
Case 1:20-cv-01288-ER
1:20-cv-01288-ER Document
Document 48
48 Filed
Filed 06/11/20
06/11/20 Page
Page 113
113 of
of 270
270
Bahamas ComCor
I am inviting you cause you are pretty and sexy and we have many friends in common that attends
or have attended our parties in the past...
Parion
Bahamas ComCor
Boned*
Bahamas ComCor
l hart a Question trial i tiate aasJung but I have to are your guest same size as you or smaller?
They wd betel ri rf they are big bonded
Ma 26,2(115 2 09 PM
Bahamas ConnCor
Hey Daniel I will add however. I have to ash are your guests no bigger than a size 5.. my boss
unfortunately has a size requirement, [f \ )</_ \ ) (/_ \ >
113
113
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 114 of 270
252. ComCor employees are specifically instructed by Nygard not to inquire about the
ages of the “pamper party” attendees. Attendees are told that there is no requirement to show ID
253. When “pamper party” invitees are hesitant to attend because they know Nygard’s
true intentions, Defendants’ ComCor employees lure and entice them with promises of “rewards.”
114
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 115 of 270
254. Upon arrival at the gated Nygard Cay and Marina Del Rey properties, each of the
potential victims is required to “register” with the Nygard Companies’ ComCor, which is in charge
of planning and coordinating corporate events, by providing their personal information, including
their name, phone number, email address, and the identity of the person who invited them.
Potential victims are also required to pose for a headshot and a full-body photograph. The pictures
and registration forms are scanned and emailed directly to Nygard, using the Nygard Companies’
255. The information is then entered into a database so that Nygard has a ready list of
“prospective recruits,” i.e., potential victims to pursue at any given time. The database contains
information and pictures of more than 7,500 girls, dating back to 1987. The database is hosted on
115
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 116 of 270
256. The most knowledgeable person about Nygard’s IT, Daane Clifford, recently died
at the age of 44 under suspicious circumstances. His family described it as a “sudden passing.”
257. The Nygard Companies’ ComCor is used to keep track of, make contact with, and
recruit, lure, and entice potential victims to the Nygard Cay and Marina Del Rey properties through
the database.
258. Nygard instructs these company-paid employees to call potential victims to invite
them to “pamper parties,” transport girls to and from the “pamper parties,” or to otherwise pay for
their transportation.
259. Nygard’s ComCor also uses corporate social media accounts to post about “pamper
parties” and send direct messages to potential victims that meet Nygard’s specifications to invite
to “pamper parties.” The Nygard Companies’ Comcor recruits these victims for Nygard and are
paid by the Nygard Companies, with funds routinely routed through New York.
116
Case
Case 1:20-cv-01288-ER
1:20-cv-01288-ER Document
Document 48
48 Filed
Filed 06/11/20
06/11/20 Page
Page 117
117 of
of 270
270
in the
the database.
261.
261. Nygard instructs his corporate ComCor to
Nygard to lure and entice potential victims to
“pamper
"pamper parties”
parties" by
by implying that
that potential modeling opportunities for the
the Nygard
Nygard Companies are
available:
rm ffferetled
Jun 1 J. 301 5. fl W tV
Bahama* ComCor
Imnoi wt'yuuiHV MfK -hrift m«t J J ift£ Q0«nrg n 14 m*l ll mjf jlhon
we W Hm modal* «t V* pety tomonow - M me Lrtow if )W idtrtiM 41
totrwij - vmi«tio«wtfieHfly i
Bahamas ComCor
yes and that you have to t>e sexy pretty and slim due to the fact that we will be scouting for
models ...
117
117
Case
Case 1:20-cv-01288-ER
1:20-cv-01288-ER Document
Document 48
48 Filed
Filed 06/11/20
06/11/20 Page
Page 118
118 of
of 270
270
i huKMnlgata •olomgMyoulw
1J 900 PM
An 13 ?0t& IUPM
Bahamas ComCor
Im not aura d you saw 9m ads yat - bm nava a SLIMS STORE opaong m xhm mat al
al • M ma know i you man m
An i J 20 8 «> PM
Bahamas ComCor
Most del
Bahamas ComCor
Bahamas ConnCor
you can invite as much female guests as you like however they have to look as hot as u due to the
fact that we normally loot for models for upcoming clothing lines..
118
118
Case
Case 1:20-cv-01288-ER
1:20-cv-01288-ER Document
Document 48
48 Filed
Filed 06/11/20
06/11/20 Page
Page 119
119 of
of 270
270
Bahamas ComCor
Im not sure 4 you saw the ads yet - but we have a SLIMS STORE opening *i Itie mal at marathon -
we are looting tor stone models at toe pamper party tomorrow let me know 4 your Mere sled in
coming - or fust to enjoy toe petty :)
Jun 13 2015 8 SO PM
Bahamas ComCor
T PM
Bahamas ComCor
ei let sept wWi beta • arc ewy sent t tar see i wn ceaSy irywg to
to ua ttw tony iwying ww
18 PM
to attend
to the “pamper
attend the "pamper parties.”
parties." They were
were required to
to provide a steady supply of sex partners for
119
119
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 120 of 270
Nygard and would recruit children and young women at shops, clubs, and restaurants. In the
Bahamas, Nygard specifically instructed them to target poor and vulnerable children and young
women from the Bahamian ghettos so that he could more easily exploit his victims. 70
264. Nygard Companies’ employees at the Nygard Cay and Marina Del Rey properties
are required to “recruit” new victims for him. If they fail to provide an adequate pool of easily
exploitable victims, Nygard punishes them by forcing them to engage in sex acts with him, verbally
berating them,71 inflicting psychological abuse, docking pay, and/or forcing them to do manual
labor. In stark contrast, those who provide Nygard with victims are paid extra by the Nygard
Companies, and they are able to avoid his wrath and sometimes avoid being his sexual victim.
Nygard’s employees and “girlfriends” “recruit” his victims to avoid these punishments and to get
into his good graces so they can avoid further victimization and receive rewards.
265. Once Nygard’s potential victims enter the Nygard Cay and Marina Del Rey
properties, the gates are locked and patrolled by security at all times. No one is allowed to leave
266. Nygard has a preference for young girls and prefers underaged victims. After he
selects his victims for the night, Nygard, either himself or through his groomers, encourages the
children and young women to drink wine, “happy juice,” or other alcoholic beverages.
267. If the young girls or women are resistant, he sometimes has his bartenders lace the
victims’ drinks with drugs such as Rohypnol—colloquially referred to as the “date rape drug” or
“roofies.”
70
https://www.nytimes.com/2020/02/22/world/americas/peter-nygard-louis-
bacon.html?referringSource=article
71
See, e.g., https://www.youtube.com/watch?v=xCa9LEJsg2I (Nygard berating security guard, Leo
Thurston); https://www.forbes.com/forbes/2010/1206/features-peter-nygard-sexual-harassment-answers-
to-no-one.html#236f0e30bc9b
120
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 121 of 270
268. Nygard then lures the victims to his bedroom or has them ushered there by
groomers, with the aid of alcohol and drugs,72 under the false pretense of discussing a potential
modeling contract in private, where he uses physical force or coercion or knowing the victim has
not attained the age of eighteen years, to engage in commercial sex acts, and coerce and force them
to engage in other unwanted sexual acts, including the following: Coprophilia, which is sexual
pleasure in feces and defecation; Urolagnia, which is sexual pleasure from the sight or thought of
urination; and Menophilia, which is sexual pleasure in a women’s menstrual cycle and period
blood.
269. In the Bahamas, Nygard’s personal security guard often stands outside the door to
his bedroom, so that nobody can enter and so that his victims cannot leave.
270. After each encounter, the victim cannot leave Nygard Cay without Nygard’s
271. Nygard Companies’ employees will often arrange for transportation to drive
272. Nygard rates or grades his victims based upon their looks and their sexual
performance and enters those ratings or grades in his victim database for future reference.
273. Nygard often pays the victims almost exclusively in the Nygard Companies’ United
States currency, based upon his ratings of the victims and the type of sex acts they were subjected
to performing.
274. The amounts of money provided to the victims is more than most of his victims
72
https://www.nytimes.com/2020/02/22/world/americas/peter-nygard-louis-
bacon.html?referringSource=articleShare
121
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 122 of 270
275. In addition to United States currency, Nygard promises that this money is just a
start to what he can provide for the victims. He promises many victims that he will contact them
276. However, in the vast majority of cases, Nygard never intends to follow through
with the modeling contracts and tells his victims this for the sole purpose of maintaining control
over them.
277. If he does provide any modeling opportunities, it is for the purpose of raping,
sexually assaulting, sexually battering, molesting them and/or compelling additional commercial
sex acts.
278. Nygard also threatens the victims with implied or express threats of retribution if
they tell anyone about what happened, often implying or expressly threatening to have his victims
279. Nygard typically does not knowingly target the same victims more than once.
280. For those victims that Nygard does attempt to contact again, however, it is only to
engage in additional commercial sex acts. Nygard, through company employees paid by the
Nygard Companies, contacts those victims whom he gave “high ratings” and attempts to get them
to attend future pamper parties. He uses a combination of his wealth, influence, power, and the
victims’ socioeconomic vulnerabilities to turn the victims into his full-time sex workers. Nygard’s
full-time sex workers are forced to act as his personal servants, satisfy his demands for sex acts,
and “recruit” new victims for him to engage in commercial sex acts with.
122
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 123 of 270
3. Nygard Uses the Nygard Companies’ Brand, Resources, and Influence and
Power in the Fashion Industry to Lure and Entice Victims to the Nygard
Companies’ Corporate Offices and Other Properties Where He Rapes,
Sexually Assaults, Sexually Batters, Molests, and Sex Traffics The Victims.
281. In addition to using “pamper parties” to lure and entice his victims, Nygard also
uses the Nygard Companies’ brand, resources, and influence and power in the fashion industry to
lure and entice victims to the Nygard Companies’ corporate offices, “executive suites,” and other
properties in Marina Del Rey, New York City, Vancouver, Montreal, Winnipeg, and Toronto.
282. Nygard has apartments and/or “executive suites” attached to or near the Nygard
Companies’ corporate offices in California, New York, Winnipeg, and Toronto. Nygard also has
offices that he has converted to bedrooms at the Nygard Companies’ office buildings. Nygard
often lures and entices young aspiring models and other young women to these properties with
283. Nygard uses the Nygard Companies’ resources to transport young women to these
locations. The women believe they are traveling to the Nygard Companies’ offices and/or
properties for job interviews for modeling and other career opportunities.
284. In truth, they are transported to the Nygard Companies’ offices and/or other
properties for the sole purpose of facilitating and enabling Nygard to rape, sexually assault,
285. Upon their arrival, the victims are further duped into believing that they are
attending job interviews for the Nygard Companies. Employees of the Nygard Companies often
usher the victims into a waiting area and offer to get them a beverage, while they wait for Nygard.
On some occasions, beverages are laced with drugs to ensure the victims’ compliance.
286. Nygard then arrives and ushers the victims into what they believe is his office. The
offices, however, contain bedrooms. Nygard closes the door behind them and prevents them from
123
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 124 of 270
leaving. He then coerces the victims into commercial sex acts and/or forcibly rapes, sexually
287. Another method that Nygard routinely uses to rape and sexually assault his victims
is to offer aspiring models to stay at his “executive suites” and/or other properties while they travel
to the Nygard Companies to interview for modeling jobs. Nygard does not disclose that the
“executive suites” and/or other properties are actually his personal apartment and/or room.
288. Once inside, Nygard’s victims are not permitted to leave without his permission.
289. Whichever method Nygard uses to lure and entice his victims, his intended purpose
is to provide for his own sexual gratification and, at the same time, benefit the Nygard Companies.
290. As set forth in the section that follows, Nygard turns some of his victims into full-
time sex workers, which he refers to as his “girlfriends,” by continuing to promise lucrative
modeling opportunities as well as providing financial benefits such as cash, clothing, jewelry, and
travel on his global fashion tours. For those he cannot turn into his “girlfriends,” Nygard threatens
them with express or implied threats of physical harm, career sabotage, and/or legal action.
Vice Chairman, Jim Bennett, Executive Vice President, Rick Wanzel, Executive Vice President
and General Manager, David Paton, Director of Systems, Greg Fenske, Marketing and Promotions
Director, Tiina Tulikorpi, CEO, Sajjad Hudda, President and CEO, Denis LaPointe, Princy
Mathew, Kevin Carkner, corporate accountant, Lili Micic, and Director of Human Resources,
Wajma Popal, have direct knowledge that Nygard uses the Nygard Companies’ brand, resources,
and position in the fashion industry to facilitate and enable the rape, sexual assault, sexual battery,
124
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 125 of 270
molestation, and sex trafficking of young women who are seeking career opportunities with the
Nygard Companies.
292. These employees and others not only turn a blind eye to Nygard’s criminal activity,
but they also directly conspire with Nygard and/or participate in his sex trafficking venture in order
to receive financial and other career benefits for themselves and the Nygard Companies.
4. Nygard Sex Traffics His “Girlfriends” and Forces Them to “Recruit” New
Victims Using Company Resources for the Benefit of Nygard and the Nygard
Companies.
293. Nygard refers to his full-time sex workers, as his “girlfriends” and his entourage
of “girlfriends” that live and travel with him at any given time as his “harem.”
294. Nygard’s “harem” consists of women from the United States, Canada, Bahamas,
and other countries. Some of his “girlfriends” are Bahamian victims who become his “girlfriends”
after first being raped at “pamper parties,” typically as children as young as fourteen years old.
295. Others are Canadian, American, and other nationalities that were lured and enticed
into becoming Nygard’s “girlfriends” by promises of modeling and other career opportunities with
296. To perpetuate his playboy image for the benefit of the Nygard Companies, Nygard
typically keeps three to four of his “girlfriends” with him at all times, including during corporate
events.
125
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 126 of 270
297. They stay with him and are forced to accompany him on trips or “tours” around the
world on the Nygard Companies’ owned “N-Force” jet,73 including to California, New Orleans,
New York, Toronto, London, Germany, Italy, and China. The Nygard Companies’ “N-Force” jet
contains mirrors on the walls and ceilings and is equipped with a bedroom and a stripper pole to
facilitate and enable Nygard’s sexual predilections, while traveling on official company business.
298. Nygard keeps tight and coercive control over his “girlfriends” through a variety of
direct and indirect manipulation tactics, including threats of force, physical intimidation and abuse,
verbal abuse, forced labor, withholding payment, and confiscating travel documents.
299. Although Nygard continues to force and coerce his “girlfriends” to engage in
commercial sex acts to satisfy his demands for sex, Nygard also uses his “harem” of “girlfriends”
to “recruit” or procure new victims for him to engage in commercial sex acts with.
73
https://corporate.nygard.com/2005/07/15/ilta-sanomat-fashion-moguls-plane-will-house-a-sauna-
private-movie-theatre-a-disco/
126
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 127 of 270
300. Nygard refers to his newly recruited victims as “fresh meat” or “sacrifices.”
Nygard has an expressed desire for children and tells his “girlfriends,” who “recruit” for him, “the
301. Nygard requires that his “girlfriends” “loosen up” his victims by giving them
302. If his “girlfriends” fail to provide Nygard with an easily exploitable victim each
night, Nygard punishes them by verbally berating them, inflicting psychological abuse,
withholding or cutting pay, forcing them to do manual labor, and forcing them to satisfy his
303. However, those who provide him with victims are paid extra for each victim and
304. Nygard’s “girlfriends” “recruit” his victims to avoid these punishments and to get
into his good graces, so they can receive rewards including, without limitation, any payments that
Nygard may be withholding. Nygard’s “girlfriends” also do so because they know that if they are
able to “recruit” a new victim for Nygard, they will not be forced to satisfy his perverse sexual
fetishes. Nygard’s “girlfriends” have “recruited” victims to engage in commercial sex acts with
Nygard in, among other places, the Bahamas, Miami, Texas, New York, Los Angeles, Canada,
305. Travel arrangements for Nygard’s “girlfriends” are made through Nygard’s
corporate travel department. While on trips, Nygard’s “girlfriends” are particularly vulnerable
because they are in unfamiliar countries, entirely dependent upon Nygard for money, and he
127
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 128 of 270
306. Nygard threatens to desert those of his “girlfriends” that do not follow his orders in
foreign countries with no money or travel documents. Those who refuse his orders are left behind
307. Initially, Nygard’s “girlfriends” are led to believe that they are traveling with him
as models on glamorous fashion tours. Eventually, they learn that they are nothing more than full-
time sex workers to Nygard that are forced to cater to all of his personal needs, including his
308. Nygard frequently takes “girlfriends” to his New York City apartment, which is
309. Nygard also regularly forces his “girlfriends” to accompany him to “swingers”
clubs in New York City. While at the “swingers” clubs, Nygard forces his “girlfriends” to find
couples for him to have sex with. He then pays and/or coerces his “girlfriends” to have sex with
other men, while he watches and engages in sex with the man’s partner.
310. While on official Nygard Companies’ “tours,” Nygard coerces his “girlfriends” to
engage in forced labor for the benefit of the companies. Nygard’s “girlfriends” are forced to be at
his beck and call and to cater to his every need 24 hours per day, 7 days per week. They must
awake every day at 5:30 a.m. to prepare his breakfast and ensure that it is ready for him to eat the
moment he awakens. They are also required to, among other things, give him his medications on
schedule, prepare his clothes, bathe him, clip his toenails, and prepare all of his meals.
311. The “girlfriends” are also required to prepare his bags with marketing and public
relations materials for his business meetings relating to the Nygard Companies, attend his business
meetings, otherwise act as his personal servants, and to model company clothing for company
128
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 129 of 270
312. The “girlfriends” are expected to constantly go out and buy the tools of Nygard’s
313. Nygard’s “girlfriends” are always paid varying amounts of cash in United States
currency from the Nygard Companies, directly by Nygard, to buy their compliance and silence.
He directs the Nygard Companies corporate accountant, Lili Micic, to make pay-offs to the
314. Nygard’s longtime “girlfriends” are also put on the official “girlfriend” or “model”
company payroll. They are paid monthly through direct deposit with funds from a Nygard
corporate account by the Nygard corporate accountant, Lili Micic. They are required to submit
invoices that state that they are being paid for “modeling and promotional services”—even though
they are full-time sex workers. These payments are made “per Mr. Nygard’s request.”
129
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 130 of 270
315. Every payment from the Nygard Companies has to be directly approved by Nygard
himself. The amount of payment is entirely conditioned upon their level of servitude to Nygard,
their ability to satisfy his sexual desires, and their ability to recruit new victims for him to engage
316. Nygard, with the help of the Nygard Companies, uses his financial resources,
influence, power in the Bahamas, and psychological manipulation to intimidate his victims and
317. Those of his “girlfriends” who try to leave him are harassed and threatened by
318. Nygard has also paid people, using Nygard Companies’ cash, to intimidate his
former “girlfriends” by slashing their tires, committing arson, threatening to arrest them, and by
5. Nygard Intentionally Uses Fraud, Coercion, and Force to Cause and Bring
About Commercial Sex Acts, Rapes, Sexual Assaults, Molestations, and Sexual
Batteries Through the Nygard Companies’ Resources.
319. Nygard’s use of fraud, coercion, and force were “used to cause,” or designed to
320. Nygard intended and was aware that the fraud, coercion, and force would cause
rape, sexual assault, sexual battery, molestation, and/or sex trafficking to take place with his
victims.
321. Nygard’s goal, as evidenced by his uniform pattern and practice, was to recruit,
entice, and lure children, knowing that they had not attained eighteen years, or women, then
employ force, fraud and/or coercion to rape, sexually assault, sexually batter, molest, and/or cause
these victims to engage in commercial sex acts for which he, through the Nygard Companies,
130
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 131 of 270
always provided something of value. The explicit or implicit quid pro quo was always intended
322. Nygard also intentionally used the Nygard Companies’ resources and brand to rape,
sexually assault, molest, or sexually batter his victims and/or entice and to cause sex acts, for which
he always provided the Nygard Companies’ resources as “value.” The Nygard Companies,
therefore, financed his commercial sex acts and facilitated and caused the rape, sexual assault,
323. The Nygard Companies also benefited from “pamper parties” and other corporate
events,74 which Nygard used to gain access to his victims, by promoting its brand and its products
324. The Nygard Companies have actual knowledge that Nygard engaged in commercial
sex acts with children and with young women by means of force, fraud, and/or coercion through
325. Other high-ranking employees of the Nygard Companies also have direct
knowledge of Nygard’s criminal activity including, without limitation, Vice Chairman, Jim
Bennett, Executive Vice President, Rick Wanzel, Executive Vice President and General Manager,
David Paton, Director of Systems, Greg Fenske, Marketing and Promotions Director, Tiina
Tulikorpi, CEO, Sajjad Hudda, President and CEO, Denis LaPointe, Princy Mathew, Kevin
Carnkner, and Director of Human Resources, Wajma Popal. Other finance personnel, including
the Nygard Companies’ corporate accountant, Lili Micic, among others, know or should know
about Nygard’s illegal activity, because they are routinely sending tens of thousands of dollars per
74
See https://ewnews.com/711-rapes-presented-to-hospitals-since-july-2013;
131
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 132 of 270
D. Consistent with His Uniform Pattern and Practice, Jane Does Nos. 1-57 Were Raped,
Sexually Assaulted, Molested, Sexually Battered, and/or Forced to Engage in
Commercial Sex Acts with Nygard by Means of Force, Fraud, and Coercion and/or
Had Not Attained the Age of Eighteen Years.
326. Jane Doe No. 1 is a Bahamian citizen born in Nassau, New Providence, the
Bahamas.
327. On July 4, 2015, Jane Doe No. 1 was walking through the Mall at Marathon,
Nassau, the Bahamas (the “mall”) with two friends. She had just turned fourteen years old.
328. The Nygard Store recently opened at the mall, and models were walking around the
329. When she approached the store, a model was standing in the entrance and asked her
to come inside. The model handed her a pair of pants and told her to try them on. Jane Doe No.
1 went to the changing room, but the changing room had no curtains or doors on them. As she
began to change, three of the workers started taking pictures. She asked if there was anywhere
else to change, and the models responded that the rooms were still being renovated, so there was
330. Jane Doe No. 1 could not fit in to the pants because they were too big. She asked
if they had any smaller sizes, and she was told that she was trying on the smallest size available.
A few minutes later, Nygard walked in and asked to take her measurements. He rubbed her inner
331. Nygard asked Jane Doe No. 1 what grade she was in, and Jane Doe No. 1 responded
332. Nygard asked her if she modeled and told Jane Doe No. 1 that she had the body for
it.
132
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 133 of 270
333. Nygard told her that his name was Peter Nygard and asked her if she wanted to
work for him. Nygard instructed her to give one of the models her phone number, and Jane Doe
334. Approximately three days later, Jane Doe No. 1 received a call from one of
335. The worker indicated that she was contacting her about the “modeling situation”
with Nygard. She was instructed to be ready at 6:00 p.m., wear a dress and heels, and do her make-
up.
336. Jane Doe No. 1 was picked-up in a white SUV at her house by another Nygard
employee. When she got in the car, there were already two girls in the back seat.
337. When they arrived at Nygard Cay, the three girls were registered at the security
338. They ate with other guests, while they waited for Nygard to join them.
340. Jane Doe No. 1 stood to the side and watched them play.
341. About ten minutes later, Nygard approached Jane Doe No. 1 and asked her if they
could go somewhere quieter to “discuss business.” Jane Doe No. 1 agreed—believing that they
342. Jane Doe No. 1 was expecting to be taken to an office and was surprised when they
entered a bedroom.
343. Jane Doe No. 1 became nervous, and Nygard assured her that he doesn’t bite and
133
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 134 of 270
344. Nygard then turned on the television, which immediately began showing
pornography. The pornography depicted a man rubbing feces over a woman’s body. Nygard
asked Jane Doe No. 1 if she was familiar with what the pornography was showing, and she
345. Nygard then went into a closet that was next to the bed and pulled out a dildo and
346. Jane Doe No. 1 responded that she could not do that and that she only came to
discuss modeling. Nygard responded that he would discuss modeling afterwards. He instructed
Jane Doe No. 1 to pick up the dildo, apply the K-Y Jelly, and to insert it into his anus.
347. Jane Doe No. 1 did not say anything because she was afraid. Nygard got onto the
bed and knelt down on his knees, turning and pointing his anus toward Jane Doe No. 1. Nygard
348. Jane Doe No. 1 did as she was instructed because she was afraid. Jane Doe No. 1
continued to penetrate Nygard’s anus with the dildo for about ten minutes, during which time
349. Nygard then told Jane Doe No. 1 that it was her turn to “have some fun.” Nygard
350. Nygard told her not to worry, reached around her neck, and began unzipping her
dress. Nygard then put on a condom and began kissing Jane Doe No. 1’s neck and began licking
351. Nygard then began to open Jane Doe No. 1’s legs as she tried to close them and
push him off her. As Jane Doe No. 1 tried to push Nygard off, he held her hands back and pinned
134
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 135 of 270
352. Jane Doe No. 1 began to cry as Nygard forced his penis into Jane Doe No. 1’s
353. After raping Jane Doe No. 1, Nygard instructed her to go into the bathroom and put
354. Jane Doe No. 1 entered the bathroom, looked in the mirror, and noticed that her
make-up was messy from crying. She cleaned her face and went back into the bedroom, at which
355. As they were walking down the stairs, Nygard handed Jane Doe No. 1 an envelope
and said, “this is for you.” Jane Doe No. 1 did not open the envelope or ask what was inside.
356. As Jane Doe No. 1 walked downstairs, she saw another young girl walking up
towards Nygard’s bedroom. When they reached the last set of stairs, Nygard left Jane Doe No. 1
357. Jane Doe No. 1 went back to the dining area where she found the two employees
who brought her there. She was escorted back to the white SUV and was transported back to her
358. When Jane Doe No. 1 got back home, she experienced extraordinary pain in her
359. She never told anyone what happened to her because she was afraid and
360. Jane Doe No. 2 is a Bahamian citizen, born in Nassau, New Providence, the
Bahamas.
135
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 136 of 270
361. In 2011, at the age of fourteen, Jane Doe No. 2 entered the Miss Teen Bahamas
362. Her family was impoverished, and they sought sponsorship to help cover her
pageant costs.
363. Because she was only fourteen, Jane Doe No. 2 was assisted by her mother, who
tried helping her find sponsorship from individuals and businesses. An ex-colleague of Jane Doe
No. 2’s mother suggested that she contact Nygard, as he might be interested in sponsoring Jane
Doe No. 2.
364. Jane Doe No. 2’s mother put together a portfolio with Jane Doe No. 2’s photographs
365. Jane Doe No. 2’s portfolio was reviewed and returned by a Nygard employee, who
informed her that Nygard was not granting sponsorships at that time.
366. Jane Doe No. 2’s mother continued to make follow-up calls to Nygard Cay, in an
367. Eventually, she developed a relationship over the phone with Nygard’s daughter,
Bianca Nygard.
368. In June 2011, Jane Doe No. 2 and her mother were invited to attend a “pamper
369. Upon arriving at Nygard Cay, Jane Doe No. 2 was registered at the ComCor office
where Nygard employees took down her contact information and photographed her.
370. Jane Doe No. 2’s mother had a conversation with Bianca Nygard about a potential
sponsorship. Bianca Nygard instructed her to re-submit Jane Doe No. 2’s portfolio.
136
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 137 of 270
371. Jane Doe No. 2 and her mother spent time at the party. Jane Doe No. 2 saw Nygard
at the party but did not have any direct contact with him.
372. Jane Doe No. 2 and her mother went home and did not have any further contact
with Nygard or his employees until August 2011, when they were invited to another “pamper
party.”
373. Jane Doe No. 2 attended the “pamper party” again with her mother. When they
entered Nygard Cay, a security guard explained to Jane Doe No. 2’s mother that she did not need
to attend the “pamper party” with Jane Doe No. 2 as she was “like family now.” Her mother stayed
anyway.
374. Jane Doe No. 2 and her mother each got pedicures at the “pamper party.” They did
not see anything unusual and returned home later that evening.
375. Approximately two weeks later, Jane Doe No. 2 received a WhatsApp text message
from a Nygard Companies’ ComCor worker inviting her to another “pamper party.”
377. Jane Doe No. 2 did not tell her mother (because she knew her mother would
disapprove) about the “pamper party” this time and she did not invite any friends to attend the
Jane Doe No. 2 was transported to the “pamper party” by a Nygard Companies’ employee.
379. When she arrived, there were a number of young girls her age, including another
380. Jane Doe No. 2 received a manicure and walked into the foyer, where she saw
Nygard sitting at a table surrounded by beautiful models. She did not approach Nygard, but noticed
137
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 138 of 270
him looking at her. As Jane Doe No. 2 talked to another girl, the Nygard Companies’ driver
381. Jane Doe No. 2 responded that she did not feel comfortable going over to talk to
Nygard. The driver told her that if she went over to talk with him, Nygard would give her a
sponsorship.
382. The driver then offered to escort Jane Doe No. 2 over to Nygard and she agreed.
383. Nygard stood up, shook Jane Doe No. 2’s hand, and told her that she was beautiful
384. Nygard asked Jane Doe No. 2 what she was drinking, and she responded that she
was drinking cranberry juice. Nygard asked her if she drank alcohol, and she responded that she
385. Nygard told her that she was at a private event and could do whatever she wanted.
386. Nygard instructed the girl sitting to his right to move and offered the seat to Jane
Doe No. 2. Nygard then instructed the bartender to bring her a glass of red wine.
387. Nygard asked Jane Doe No. 2 about herself. Jane Doe No. 2 explained that she
already sent him her portfolio and he rejected it. Nygard responded that had he known how
388. Before Jane Doe No. 2 finished her first glass of wine, Nygard instructed the
bartender to bring her a second glass. Jane Doe No. 2 continued to drink wine as they talked at
the table.
389. Nygard asked Jane Doe No. 2 if she wanted to be a model. He also told her that if
she stuck with him, she could travel all over the world with him. He pointed to several other
138
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 139 of 270
women in the room who were his models and traveled with him to fashion shows in New York
and London.
390. Jane Doe No. 2 had two more glasses of red wine, which Nygard instructed the
391. Eventually, Nygard called the bartender over and whispered in his ear. The
bartender returned with a bag of pills. There were white, blue, and pink pills all in a small blue
zip-locked bag.
392. Nygard showed the bag to Jane Doe No. 2 and told her that the pills would help her
become a model, because all models did them. He told her that the pills would make her feel good
393. Nygard handed her the three pills and instructed her to take them all at once. Jane
394. Approximately fifteen minutes after taking the pills, Jane Doe No. 2 got up to use
the restroom. While in the restroom, she began to feel dizzy, and the room began to spin.
395. She returned to the table where another glass of wine was waiting for her.
396. Nygard then escorted her away from the foyer area, holding her hand, and led her
to his bedroom. Once they arrived in his bedroom, Nygard laid her down on the bed and told her
to relax.
397. He walked away for approximately five minutes and returned with a dildo in his
hands.
398. He removed Jane Doe No. 2’s pants and underwear and attempted to force the dildo
139
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 140 of 270
399. Jane Doe No. 2 resisted and told Nygard to stop because it hurt, but Nygard did not
stop.
400. Nygard instructed her to “relax” and stated that “it has to be done sooner or later.”
401. At that point Jane Doe No. 2 blacked out and does not know what Nygard did to
402. The next morning, Jane Doe No. 2 awoke and saw Nygard still sleeping next to her
in the bed. She immediately got out of the bed and noticed blood on the sheets.
403. She went to the bathroom and immediately cleaned herself up. There was blood
404. When she came out of the bathroom, she noticed her pants and underwear on the
floor. Nygard was awake and told her that her life was “going to be different” now.
405. He then reached over to a dresser next to the bed and handed her approximately
406. Nygard instructed her not to tell anyone what happened and told her that he would
407. Jane Doe No. 2 initially refused to take the money, but Nygard insisted that she
take it.
408. Nygard asked her if she wanted him to have one of his drivers take her home, but
she declined.
409. Jane Doe No. 2 called her aunt to pick her up at a nearby mall.
410. At that point, Nygard’s personal assistant, a Nygard Companies’ employee, came
140
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 141 of 270
411. Jane Doe No. 2 was escorted to a black bus that had a picture of Nygard’s face on
it. She was the only person on the bus, and the driver took her to the Charlottesville shopping
412. Jane Doe No. 2’s aunt then picked her up from there and drove her home.
413. Jane Doe No. 2 was a virgin prior to being raped by Nygard.
414. In November 2011, Jane Doe No. 2 was invited to another “pamper party” via text
415. She decided to go to the “pamper party,” because she believed that Nygard would
416. When she arrived at the “pamper party,” Nygard approached her and asked her how
she was doing. He began instructing the bartender to bring her wine again. He again offered her
418. When they arrived, Nygard instructed Jane Doe No. 2 to play with his genitals, gave
her lubricant and a dildo, and told her to penetrate his anus.
419. Afraid, and hoping for the modeling opportunity that Nygard had promised her,
420. Later, Jane Doe No. 2 received text messages from a Nygard Companies’ ComCor
employee inviting her to travel with Nygard to Ohio, Canada, and New York.
421. After the November 2011 “pamper party,” Jane Doe No. 2 began receiving regular
422. Jane Doe No. 2 became a regular guest, on the hope that she would become an
141
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 142 of 270
424. In 2015, Nygard launched his Nygard Slims brand, and Jane Doe No. 2 modeled
the pants at the grand opening of the Nygard store at the Marathon Mall.
425. She was given a check for over $3,000 from the Nygard Companies. After
grooming and abusing Jane Doe No. 2, Nygard converted her into a “recruiter” to secure other
426. Jane Doe No. 2, still a minor, did so, in order to avoid having to satisfy Nygard’s
427. Nygard would instruct Jane Doe No. 2 to offer the young girls drugs.
428. If the girls did not want to sleep with Nygard, Jane Doe No. 2 would sometimes put
the drugs in their drinks or food without their knowledge and at Nygard’s direction.
429. Jane Doe No. 2 has first-hand knowledge of other girls who Nygard had delivered
430. Each time Jane Doe No. 2 visited Nygard Cay and “recruited” girls for him, Nygard
would give her large sums of cash—never less than $2,000 and always in U.S. currency (from the
Nygard Companies).
431. On February 7, 2017, Jane Doe No. 2 went to Nygard Cay to attend another
“pamper party.”
432. They played poker until very late, and Nygard invited her to his room.
433. Nygard then insisted that Jane Doe No. 2 defecate and/or urinate in his mouth.
434. Jane Doe No. 2 responded that she did not wish to do that to him. He offered to
give Jane Doe No. 2 drugs that would help her to defecate.
142
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 143 of 270
435. Jane Doe No. 2 told Nygard no and decided she could no longer take Nygard’s
436. Jane Doe No. 3 is a Bahamian citizen, born in Nassau, New Providence, the
Bahamas.
437. In June 2011, she was fifteen years old, when she met one of Nygard Cay’s ComCor
employees.
438. The employee frequented Jane Doe No. 3’s neighborhood. The employee
439. She stated that she had a job for them to do, but did not specify what the job was.
440. She told Jane Doe No. 3 to be ready the next day and that someone would pick her
up.
441. The next day, at approximately 1:00 p.m., a white SUV arrived at Jane Doe No. 3’s
442. When she arrived, she saw the employee, who told her that the job was not ready
443. Jane Doe No. 3 was taken to the spa and given a professional massage. It was her
444. After the massage, Jane Doe No. 3 had lunch with some of the other guests.
445. The employee arrived and told her that she wanted her to meet someone. Jane Doe
No. 3 followed the employee upstairs to Nygard’s bedroom, where she was introduced to Nygard,
143
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 144 of 270
446. Nygard began a conversation with Jane Doe No. 3, at which point the employee left
the room.
448. After another glass of wine, Nygard asked Jane Doe No. 3 if she had ever had sex
450. Nygard took her over to the bed and began to rub her legs and face.
451. He sat down next to her and slowly pushed her body back onto the bed. Nygard
452. He began kissing her on her stomach and she began trembling in fear.
453. She shouted “no” and began to cry. Nygard grabbed her closer, put all of his weight
454. She told him to stop and resisted him, but he overpowered her.
455. After Nygard raped her, Jane Doe No. 3 was bleeding from her vagina, and there
456. Jane Doe No. 3 told Nygard that she wanted to go.
457. He pointed her toward the bathroom and told her to clean off.
458. She took a shower, and when she finished, Nygard was no longer in the room.
460. Eventually, the employee returned and asked her if she was okay. She responded
that she was afraid. The employee led her back downstairs, and Jane Doe No. 3 sat by herself until
144
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 145 of 270
461. Before Jane Doe No. 3 left, the employee handed her approximately $200 in U.S.
currency.
462. The following week, some of Jane Doe No. 3’s friends showed her a text message
from the employee, instructing them to be ready to go to Nygard Cay that Sunday.
463. The next day, Jane Doe No. 3 told her fourteen-year-old cousin, Jane Doe No. 4,
about the employee and the “pamper party” at Nygard Cay. She did not, however, tell Jane Doe
464. Jane Doe No, 3 and Jane Doe No. 4 went to Nygard Cay.
465. When they arrived, they were registered at the security station near the front gate.
466. Inside, Jane Doe No. 3 was not feeling well, so she sat by herself, while the other
467. Jane Doe No. 3 went to the bathroom, and, when she returned, she did not see Jane
Doe No. 4.
468. She asked one of the other girls at the pamper party where she went, and they told
469. Later, someone told Jane Doe No. 3 that her mother was outside the gate at Nygard
Cay, threatening to call the police if they did not let her in to get the girls.
470. She did not want to leave without Jane Doe No. 4, and she was very scared.
472. Jane Doe No. 4 stated that she needed to go get her bag, which she left at the pool
area. She returned a short time later, and they ran toward the gate, where they saw Jane Doe No.
473. They immediately got in the car, and she drove them home.
145
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 146 of 270
474. Neither Jane Doe No. 3 nor Jane Doe No. 4 told Jane Doe No, 3’s mother what had
happened to them at Nygard Cay. Instead, they told her that the employee had offered them jobs
476. Jane Doe No. 4 is a Bahamian citizen, born in Nassau, New Providence, the
Bahamas.
477. In June 2011, she was fourteen years old when her cousin, Jane Doe No. 3, told her
479. At the party, Jane Doe No. 4 went to the pool house and changed into her bathing
suit. She went to a beach chair and sat there with her bag next to her.
480. After about 30 minutes, she went and got a manicure and pedicure. She returned
481. Shortly thereafter, Nygard approached her and asked her if she had ever thought
about modeling.
482. He told her that he thought that she would be a good candidate, based upon her
body structure. He then told her that he had connections, if she wanted to try it.
483. Nygard asked her if she wanted to go somewhere quieter to talk and motioned for
484. He led her up the stairs, at which point Jane Doe No. 4 began to hesitate. He told
her not to be scared. She followed him up the stairs and into his bedroom.
146
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 147 of 270
485. Once they arrived in the bedroom, Nygard invited her to get comfortable on the
bed.
486. Nygard turned on the television, which was playing pornography showing a woman
487. After some time, Nygard sat down on the bed next to her and began stroking her
hair and rubbing her back. Jane Doe No. 4 was scared and uncomfortable.
488. She asked him if this was his way of talking about modeling, and he replied that he
489. Nygard began removing his clothes and moved toward her. Nygard pulled the
strings on her bathing suit, removing it, and began licking her neck, moving downward until he
490. Jane Doe No. 4 attempted to close her legs, but Nygard pushed them open. She
491. Nygard then moved upward and began to penetrate her vagina with his penis.
492. After some time, he then instructed her to perform oral sex on him until he
ejaculated.
494. Jane Doe No. 4 then went into the bathroom and took a shower. She put her clothes
on, and when she came out, Nygard gave her a white envelope and told her “this is for you.”
495. Nygard then told her to give him his contact information and that he would contact
her about modeling. The envelope contained approximately $5,600 in U.S. currency.
496. Jane Doe No. 4 left the room, and as she was heading downstairs, she saw her
cousin, Jane Doe No. 3, looking for her and saying that her mother was outside waiting for them.
147
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 148 of 270
497. Jane Doe No. 4 returned to the pool area to get her bag, and they left together with
499. Jane Doe No. 5 is a Bahamian citizen, born in Nassau, New Providence, the
Bahamas.
500. In July 2009, when she was seventeen years old, she was invited to a “pamper
501. While at the party, Jane Doe No. 5 consumed multiple alcoholic beverages.
502. While they were drinking on the beach, Nygard approached the friend and gestured
503. The friend motioned to Jane Doe No. 5 to come with her because she did not want
504. Nygard took them up to his bedroom and gave them more to drink.
505. After drinking the drinks, Jane Doe No. 5 began to feel different.
506. Nygard instructed the girls to touch one another sexually, and they complied.
507. After several minutes, Nygard joined and began touching the girls.
508. Nygard then sodomized Jane Doe No. 5 against her will.
510. Nygard then asked the girls to defecate on him, but neither of them could or would
do so.
511. Nygard gave Jane Doe No. 5 $200 in U.S. currency and led the girls downstairs.
512. He gave permission for them to leave, and they drove home.
148
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 149 of 270
514. Jane Doe No. 6 is a Bahamian citizen, born in Nassau, New Providence, the
Bahamas.
515. In August 2008, when she was fifteen years old, she was invited to a “pamper party”
516. Upon arriving, she was processed and registered in the ComCor database and her
517. While at the party, Jane Doe No. 6 had multiple alcoholic beverages.
518. Jane Doe No. 6 also saw several other children that she knew at the party.
519. Jane Doe No. 6 was introduced to Nygard. Within minutes of the introduction,
520. Later in the evening, Nygard invited Jane Doe No. 6 to accompany him to get some
marijuana to smoke.
521. Jane Doe No. 6 was not afraid because Nygard had a high profile in the Bahamas,
522. Nygard took her up to his bedroom. He then undressed and went into the Jacuzzi.
523. Jane Doe No. 6 began to feel lightheaded from the alcoholic drinks that she had
consumed.
524. Nygard got out of the Jacuzzi and told Jane Doe No. 6 to get comfortable.
75
See https://www.youtube.com/watch?v=SVQADmCs77s (detailing unveiling of Nygard Cay “beach
disco.”).
149
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 150 of 270
525. Nygard opened a drawer filled with pills and told Jane Doe No. 6 to take some, but
she declined.
526. Nygard then untied her bathing suit and began undressing her.
527. He told her that he wanted her to defecate on his face, and she told him no.
528. Nygard began fondling Jane Doe No. 6 and pushed his finger into her anus.
529. Jane Doe No. 6 tried to fight Nygard off, but he became more aggressive the more
530. He then attempted to sodomize Jane Doe No. 6 but was unable to penetrate her
anus.
532. Jane Doe No. 6 told Nygard to stop many times and continued to fight, but he
overpowered her.
533. After Nygard was done, Jane Doe No. 6 got dressed immediately and tried to leave
the room. Before she could leave Nygard told her to take a handful of cash in U.S. currency.
534. Jane Doe No. 6 refused the cash and left the room.
535. She found her friends and left Nygard Cay. She never returned.
537. In 2010, when she was 18 years old, Jane Doe No. 7 was invited to a “pamper party”
538. Upon arrival, she was processed and registered in the ComCor database and her
539. Jane Doe No. 7 consumed several alcoholic beverages while at the party.
150
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 151 of 270
540. Nygard approached her and introduced himself to her. He then led her upstairs to
the bedroom.
541. Nygard invited Jane Doe No. 7 into the Jacuzzi, and she got in.
542. Nygard made sexual advances toward her in the Jacuzzi, and she resisted.
543. Nygard then made a drink for Jane Doe No. 7, which she drank completely.
544. Within several minutes, Jane Doe No. 7 began feeling nauseous and sleepy.
546. Jane Doe No. 7 then bent over the bed because she could no longer stand. Nygard
547. Jane Doe No. 7 does not recall what happened next because she kept slipping in
548. She awoke with pain in her anus and blood in her underwear.
549. Nygard paid Jane Doe No. 7 in U.S. currency and sent her away.
551. Jane Doe No. 8 is a Bahamian citizen. In 2008, Jane Doe No. 8 was an employee
of Nygard Cay.
552. Jane Doe No. 8 was often tasked with driving to pick up girls who didn’t have a
ride to a pamper party, hosting pamper parties, recruiting women for pamper parties, and
553. Jane Doe No. 8 was aware of Nygard’s sexual appetites, since she often was the
one picking up victims and driving them to and from Nygard Cay.
151
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 152 of 270
554. She herself had turned down Nygard’s sexual advances many times during the
555. On one particular occasion in 2014, after substantial stress at the job, one of
Nygard’s “girlfriends” offered her a glass of wine. The girlfriend was insistent, and, although Jane
Doe No. 8 rarely drinks while at work, she accepted a glass of wine and gulped it down quickly.
556. Shortly after arriving, she noticed her arms become numb and then she fell
557. When she became alert again, Nygard was on top of her on his bed and was in the
act of penetrating her vaginally with his penis. She was powerless to stop him.
558. While slipping in and out of consciousness, Jane Doe No. 8 saw three specific
girlfriends walk in and witness what was happening, including the girlfriend who provided her the
wine.
559. When Jane Doe No. 8 finally became fully awake, she left the household, went out
560. After this occurred, she continued to work at Nygard Cay out of financial necessity.
561. Following Nygard’s rape of her, Jane Doe No. 8 actively attempted to avoid contact
with Nygard and performed all the household duties she could that did not require direct contact
with him.
562. Nygard finally confronted her about the rape and told her “not to take it personally.”
563. Eventually, Nygard told Jane Doe No. 8 that she must either continue to have sex
with him regularly, or that she would no longer be employed. When she refused, she was
terminated.
152
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 153 of 270
564. On April 6, 2017, Jane Doe No. 8 was taking the trash out at her home in the
Bahamas, when she was accosted by two of Nygard’s employees. The two employees stated that
Nygard wanted to speak to her and that she needed to travel to see him. She stated that she did not
wish to see Nygard. The employees ignored her refusal and used physical force to take her inside,
confiscate her passport, and put her into a car. She had no clothes or travel items with her.
565. Jane Doe No. 8 was driven by the two employees to the airport and given a plane
566. When she arrived in Toronto, Jane Doe No. 8 was only wearing shorts and a t-shirt
and was freezing. She was forced into a hotel room and restrained or guarded to prevent escape.
567. During this time, her cell phone was confiscated, and she was not allowed to let her
568. Nygard, however, did not appear in Toronto and the employees who abducted her
provided plane tickets and, at Nygard’s instruction, took her to Fort Lauderdale.
569. In Fort Lauderdale, Jane Doe No. 8 was restrained and guarded in another hotel
570. Nygard again did not appear in Fort Lauderdale and Jane Doe No. 8 was flown back
571. Jane Doe No. 9 was an employee of Nygard and the Nygard Companies.
572. During her time as an employee of Nygard and the Nygard Companies, Jane Doe
No. 9 was sexually assaulted by Nygard on numerous occasions. On each occasion, she would
resist and tell him no, but he would force himself on her.
153
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 154 of 270
573. Nygard used Jane Doe No. 9’s continued employment with the Nygard Companies
as value and as a means to coerce and force her into commercial sex acts.
574. In 2015, Jane Doe No. 9 was sexually assaulted by Nygard at his residence in
575. She was asleep in a guest room that had a key code lock on the door. Nygard
overrode the key code and entered the room without her permission while she was sleeping.
576. She awoke to Nygard forcefully and physically overpowering her as she attempted
577. She verbally demanded he stop, but he refused and proceeded to forcefully
penetrate her.
578. After the assault, Jane Doe No. 9 sought medical treatment.
579. Jane Doe No. 9 eventually left her employment with Nygard and the Nygard
580. She did not report Nygard’s sexual abuse because she is extremely scared of him
581. Jane Doe No. 10 is a Bahamian citizen. In the summer of 2004, when she was
fifteen years old, Jane Doe No. 10 was vaginally raped and sodomized by Nygard while attending
582. Jane Doe No. 10 had heard of “pamper parties” before from her friends and thought
583. When she was fifteen years old, her sister invited her to come to a “pamper party”
at Nygard Cay.
154
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 155 of 270
584. After eating sushi and grilled meats, Jane Doe No. 10 noticed that she was not
585. She was approached by Nygard and his security guard shortly thereafter.
586. Nygard held Jane Doe No. 10’s hand and told her to follow him.
587. Jane Doe No. 10 asked why, but Nygard refused to answer and dragged her along
with him.
588. Nygard’s security guard walked with them as they arrived at what Jane Doe No. 10
589. After she and Nygard entered the bedroom, Nygard’s security guard stood outside
his door.
590. Once they were alone in the room, Nygard commented on Jane Doe No. 10’s body,
told her that she could be a model for him, and cupped her butt with his hands.
592. Jane Doe No. 10 told Nygard that she was not comfortable doing that, as she was
593. Jane Doe No. 10 was still not feeling well and was feeling dizzy and light-headed.
594. Jane Doe No. 10 told Nygard that she was not feeling well and that she was ready
to go home.
595. Nygard opened a drawer and took out a small white pill. He told Jane Doe No. 10
to take the pill, lay down, and it would make her feel better.
596. Jane Doe No. 10 took the pill, thinking that it would make her feel better.
597. Nygard then asked Jane Doe No. 10 if she had ever had anal sex before. She told
155
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 156 of 270
598. Nygard told Jane Doe No. 10 that she was going to like it and offered her $5,000.
599. Nygard then forced Jane Doe No. 10 onto the bed and climbed on top of her, kissing
600. Jane Doe No. 10 told him that he was making her feel uncomfortable.
601. Jane Doe No. 10 tried to fight Nygard off of her, but he physically overpowered
603. Nygard then forced his penis into her vagina. It was very painful and Jane Doe No.
10 began to cry.
604. Jane Doe No. 10 told Nygard that he was hurting her and that she was still not
feeling well.
605. Nygard told Jane Doe No. 10 to lay down on her stomach and she would feel better.
606. Jane Doe No. 10 laid down on her stomach and Nygard immediately laid on her
607. Nygard then offered Jane Doe No. 10 $10,000 to defecate in his mouth. Jane Doe
No. 10 responded that she could not do that and that she was in a lot of pain.
608. Nygard then forced his penis into Jane Doe No. 10’s anus.
609. When he was done Jane Doe No. 10 immediately left the room and went downstairs
to her sister.
610. Jane Doe No. 10’s sister could tell that she was visibly upset, but she did not tell
611. They went home and Jane Doe No. 10 did not tell anyone what had happened
156
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 157 of 270
612. Jane Doe No. 10 woke up the following day and she was bleeding from her anus.
She was too afraid to tell her mother, so she asked her sister to accompany her to the doctor.
613. Jane Doe No. 10 had to receive two stitches in her anus to stop the bleeding.
614. Jane Doe No. 11 is a Bahamian citizen. In 2002, when she was fifteen years old
Jane Doe No. 11 was first raped by Nygard. Jane Doe No. 11 became a regular “girlfriend” of
615. In 2002, Jane Doe No. 11 was first invited to a “pamper party” at Nygard Cay by
616. “Shorts” drove Jane Doe No. 11 to the “pamper party.” Upon arrival, she was
registered with ComCor at the security gatehouse and they took her photograph.
617. While at the “pamper party,” Jane Doe No. 11 was served and consumed alcoholic
beverages.
618. As the “pamper party” was coming to an end, Jane Doe No. 11 began looking for
619. “Shorts” left the party without Jane Doe No. 11, effectively stranding her at Nygard
Cay.
620. Jane Doe No. 11 met Nygard and asked Nygard if he could assist her in getting a
ride home. Nygard informed her that the gates were locked and that she could not leave until
morning.
621. Nygard then began making sexual advances toward Jane Doe No. 11.
622. Jane Doe No. 11 told Nygard that she wanted to go home, but he told her that she
157
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 158 of 270
623. Nygard told Jane Doe No. 11 to follow him and he would show her to a room that
624. Jane Doe No. 11 followed Nygard. Nygard led Jane Doe No. 11 to his bedroom.
625. Nygard began touching Jane Doe No. 11, who asked him to stop. He then put on
coprophilia pornography and demanded oral sex from Jane Doe No. 11, who again refused.
626. At this point, Nygard became angry with her, threw her on the bed, and
overpowered her. He attempted to sodomize her and then vaginally raped her.
627. During the rape, Nygard demanded that Jane Doe No. 11 defecate and urinate on
628. Jane Doe No. 11 was a virgin before Nygard raped her.
629. Nygard did not use a condom and gave Jane Doe No. 11 a “Plan B” so that she
630. Eventually Nygard fell asleep. Jane Doe No. 11 escaped his bedroom, ran
631. Jane Doe No. 11 did not know where she was and kept getting lost. She walked for
632. Jane Doe No. 11 asked the security guards at the gate to help her with a ride home
633. Jane Doe No. 11 did not tell anyone what happened to her due to embarrassment,
634. Jane Doe No. 11 began receiving Facebook messages from Nygard’s ComCor
158
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 159 of 270
635. Jane Doe No. 11 attended other “pamper parties” with friends. She believed that if
636. Nygard, however, raped Jane Doe No. 11 on several occasions when she attended
637. In 2005, Jane Doe No. 11 started attending the “pamper parties” again. She
attended the “pamper parties” regularly until approximately 2008 and became one of Nygard’s
638. Nygard forced Jane Doe No. 11 to have sex with him, other girls, and other men.
639. Jane Doe No. 12 is Bahamian citizen born in Nassau, the Bahamas. For
approximately six years, from 2008-2014, she was paid as a full-time sex worker and “girlfriend”
of Nygard.
640. Jane Doe No. 12 was paid to engage in sex with Nygard and others.
641. She was also paid to “recruit” young girls and women for Nygard to rape and/or
engage in commercial sex acts with. She recruited young girls and women in various locations
around the world, including the United States and the Bahamas.
642. Nygard gave Jane Doe No. 12 specifications about what type of girls and women
he wanted her to introduce to him. Nygard told her he wanted the girls to be slim and “the younger,
the better.”
643. In 2008, Jane Doe No. 12 attended a “pamper party” at Nygard Cay. She was
159
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 160 of 270
644. She learned of the “pamper party” through one of Defendants’ ComCor employees.
The woman told Jane Doe No. 12 that there would be free food and drinks at the party and she
645. Jane Doe No. 12 was interested in having professional modeling photos taken and
646. Upon arrival, Jane Doe No. 12 was registered with ComCor.
647. The ComCor employee who invited Jane Doe No. 12 to the “pamper party”
648. Nygard offered to show Jane Doe No. 12 around the property. The “tour” ended in
Nygard’s bedroom.
649. Nygard invited Jane Doe No. 12 to join him in the jacuzzi. Jane Doe No. 12
650. Nygard began performing oral sex on Jane Doe No. 12. He then led Jane Doe No.
12 to the bed. Nygard requested that Jane Doe No. 12 defecate in his mouth, to which she said no.
Nygard then placed grapes in her anus and asked her to push them out into his mouth. Nygard
651. When he was finished, Nygard handed Jane Doe No. 12 a “morning after pill” from
his nightstand and instructed her to take it so she would not get pregnant.
652. Nygard then went to his safe and gave Jane Doe No. 12 between $500 and $1000
in U.S. currency and told her it was “cab fare.” Jane Doe No. 12 understood this to be “hush
money.”
653. Nygard and Jane Doe No. 12 exchanged phone numbers. Jane Doe No. 12 saw that
Nygard “rated” each of the girls in his phone based on his sexual experience with them.
160
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 161 of 270
654. Jane Doe No. 12 returned to the “pamper party” for a few hours where she enjoyed
655. Shortly after the first “pamper party,” Nygard began texting Jane Doe No. 12 to
656. Jane Doe No. 12 attended dinner parties at Nygard Cay on several occasions.
657. Nygard sat Jane Doe No. 12 next to him at the table and paid special attention to
her. Jane Doe No. 12 later learned that this was typical with new “recruits.”
658. A few weeks later, Nygard invited Jane Doe No. 12 to go on a trip with him and
659. Nygard portrayed the trips as fun and glamourous “fashion tours.”
660. Jane Doe No. 12 accepted the invitation and her trip was booked through
661. On her first trip with Nygard, Jane Doe No. 12 and other “girlfriends” flew on
Defendants’ “N-Force” jet to New Orleans, then to Los Angeles, and lastly to New York.
662. While in New Orleans, Jane Doe No. 12 shared a room with another “girlfriend”
whose job it was to train Jane Doe No. 12 how to do the job. She was instructed that Nygard
expects “good behavior,” meaning she had to bring him new girls, called “presents,” and the
younger the better. She would get more favor from Nygard if the victim was younger. She was
also told she would be expected to have sexual experiences with a lot of men for Nygard’s viewing
pleasure.
663. When the group arrived in Los Angeles, they were taken to Nygard’s Marina Del
161
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 162 of 270
664. Soon after, Nygard summoned Jane Doe No. 12 to his room. Another couple was
in the room as well, named Steve and Sophie. Jane Doe No. 12 and the other female began to
engage in a sexual experience with each other. At some point, Nygard offered Jane Doe No. 12 to
Steve for sex so that Nygard could have sex with Sophie. Jane Doe No. 12 did not want to engage
in sexual intercourse with Steve, however she did not have a choice in the matter, and cried after
it was over.
665. Jane Doe No. 12 talked to her roommate about what happened. The roommate told
666. Nygard held a “pamper party” while they were at Marina Del Rey and the
roommate showed Jane Doe No. 12 how to recruit new girls at a “pamper party” for Nygard.
667. In New York City, Nygard took Jane Doe No. 12 to a “club.” Nygard, Jane Doe
No. 12, and the other girls were driven to the club by the Nygard Companies’ driver. Jane Doe
No. 12 thought they were just going to a regular dance club. Upon arrival, Jane Doe No. 12 was
668. Jane Doe No. 12 was forced and coerced to have sex with other men at the
“swingers” club in New York City at Nygard’s direction and for his benefit.
669. After New York City, Jane Doe No. 12 flew to Toronto with Nygard. Eventually,
Jane Doe No. 12 told Nygard that she wanted to go home because the “fashion tour” was not what
670. Nygard would not permit Jane Doe No. 12 to go home and told her that she needed
to “recruit” other girls and women for him to have sex with.
671. Jane Doe No. 12 was dependent upon Nygard for money and travel.
162
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 163 of 270
672. Nygard forced Jane Doe No. 12 to attend a “swingers club” in Toronto where she
was coerced and directed by Nygard to “recruit” couples for she and Nygard to have sex with.
673. After Toronto, Jane Doe No. 12 flew back to the Bahamas with Nygard on
674. Jane Doe No. 12 wanted to go home, but Nygard required her to stay at Nygard
Cay because he was throwing a “pamper party” the day that they landed in the Bahamas.
675. Jane Doe No. 12 did not go home because she knew that if she left Nygard would
676. Nygard allowed Jane Doe No. 12 to go home after she “recruited” a woman at the
“pamper party” for Nygard to have sex with and ushered her to Nygard’s room.
677. By the end of her first trip with Nygard, Jane Doe No. 12 realized that she was
traveling with Nygard as a full-time sex worker—not as a model as he promised—and that his
portrayal of the “fashion tours” were used to exploit Jane Doe No. 12 and the other “girlfriends”
678. Jane Doe No. 12 only got to model for Defendants a few times when he had his
“girlfriends” wear his new line of clothing to show executives of the Nygard Companies.
679. Nygard had strict physical appearance rules for his “girlfriends.” Girlfriends
always had to have full hair and makeup done, heels had to be worn, no red lipstick allowed, certain
hair styles were not allowed, and at times, Nygard would dictate the outfits worn.
680. Nygard had strict dietary conditions for his “girlfriends” to ensure they remained
extremely slender.
681. Throughout the six years that Jane Doe No. 12 was Nygard’s “girlfriend,” she was
regularly paid on a monthly basis and coerced to engage in commercial sex acts with him including
163
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 164 of 270
vaginal sex and anal sex. Nygard also paid and coerced Jane Doe No. 12 to defecate in his mouth.
In addition to having sex with strangers at “swingers clubs,” Nygard also forced Jane Doe No. 12
to have sex with other men in New York, Los Angeles, and the Bahamas. Nygard typically paid
Jane Doe No. 12 $1,200 in U.S. currency for engaging in sex acts with other men.
682. Jane Doe No. 12 was paid and coerced to “recruit” other young girls and woman
for Nygard to have sex with. Nygard told Jane Doe No. 12 that if she brought him new victims,
683. By 2009, Jane Doe No. 12 became one of Nygard’s “main” sex workers.
684. During the time she was working, she was forced to cater to Nygard’s perverse
sexual desires twenty-four hours per day, seven days per week.
685. While employed as Nygard’s “girlfriend,” Jane Doe No. 12 often traveled with
Nygard and several other “girlfriends” to and from various locations including New York City,
Los Angeles, Miami, New Orleans, Winnipeg, Toronto, London, and cities in China and Germany.
686. Jane Doe No. 12 “recruited” woman for Nygard in all of these locations.
687. Nygard instructed Jane Doe No. 12 to “loosen up” the “recruits” and make sure
they are willing to comply with Nygard’s sexual demands. If a girl was not willing, Nygard
expected Jane Doe No. 12 to participate in the sexual act to make her more comfortable.
688. Other times, she witnessed Nygard employees drug certain food and beverages at
689. Sometime in 2009, Jane Doe No. 12 was put on the Nygard Companies’ official
“girlfriend” or “model” payroll and was paid approximately $3,000 to $4,000 per month to
engaged in commercial sex acts with Nygard and others as well as “recruit” new victims for
Nygard.
164
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 165 of 270
690. Jane Doe No. 12 was paid by the Nygard Companies via direct deposit through
691. Jane Doe No. 12 was also periodically given cash from the Nygard Companies
directly by Nygard.
692. Beginning in 2011, the Nygard Companies’ corporate accountant, Lili Micic,
instructed Jane Doe No. 12 to submit invoices in order to receive her monthly payments. She
provided Jane Doe No. 12 with an invoice template that stated that she was being compensated by
693. All payments made by Lili Micic were required to be approved directly by Nygard.
694. In February 2012, Jane Doe No. 12 became sick for nearly a month, while traveling
with Nygard to Toronto and was hospitalized. Tina Tulikorpi, Marketing and Promotions Director
of the Nygard Companies, arranged for the Nygard Companies to pay for Jane Doe No. 12’s
hospital bills.
695. Nygard used the payment of Jane Doe No. 12’s hospital bills as further means to
696. In 2012, Jane Doe No. 12 travelled to China with Nygard and several other
“girlfriends.” While in China, Nygard became enraged with Jane Doe No. 12 and almost
committed physical violence against her until another “girlfriend” stepped in.
697. Nygard would sometimes offer Jane Doe No. 12 to visitors, business professionals,
politicians, or guests of his for a commercial sexual act. This occurred in the Bahamas, in the
698. On one occasion, Jane Doe No. 12 was sent by Nygard to Perry Christie’s office to
“ask for help” with a personal matter. When she arrived, Christie had “sexy” photos of her, that
165
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 166 of 270
she had taken for Nygard, spread across his desk. Christie took his penis out and attempted to
engage in sexual activity with Jane Doe No. 12. Jane Doe No. 12 refused. Afterwards, Nygard
asked about Jane Doe No. 12’s encounter with Christie and became upset when he learned that
Jane Doe No. 12 did not have sexual intercourse with Christie.
699. In 2014, Jane Doe No. 12 grew tired of working as a sex worker for Nygard. She
had a legitimate business that she could rely on for income so she decided to quit.
700. Nygard threatened her physically, paid Bahamian police to harass and threaten her,
paid thugs to firebomb her business, and threatened to sue Jane Doe No. 12 if she exposed
701. Jane Doe No. 12 is terrified that Nygard will attempt to retaliate against her for
coming forward.
703. In the summer of 2007, when she was seventeen years old, Jane Doe No. 13 traveled
704. Jane Doe No. 13 met with a modeling manager to discuss representation.
705. The modeling manager took Jane Doe No. 13 to his apartment and they discussed
him representing her for modeling and acting in the United States.
706. The modeling manager told Jane Doe No. 13 that he had a very important friend in
the fashion business named Peter Nygard that he hoped Jane Doe No. 13 could meet with and
707. The modeling manager told Jane Doe No. 13 that he needed to take pictures of her
to send to him.
166
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 167 of 270
708. As he was photographing Jane Doe No. 13, the modeling manager told her that he
needed to take nude photos because the man would be considering her for an upcoming swimsuit
709. The modeling manager sent the photographs of Jane Doe No. 13 to Nygard for his
“approval.” He then told Jane Doe No. 13 that she was “in luck” because Nygard wanted to meet
her.
710. The modeling manager took Jane Doe No. 13 to Nygard’s penthouse apartment in
711. When she arrived, there were several other girls and a few men in the apartment as
712. Jane Doe No. 13 was given alcohol including champagne and liquor. She was
encouraged by both the modeling manager and the staff to keep drinking.
713. After about an hour, Jane Doe No. 13 was taken to the bedroom where Nygard was
waiting.
714. Nygard asked Jane Doe No. 13 her age and she replied that she was seventeen.
715. Nygard told Jane Doe No. 13 that he thought she would be a good fit for a photo
716. Jane Doe No. 13 lost consciousness shortly thereafter because her drinks were
717. Jane Doe No. 13 woke up on her stomach, her dress pulled up above her waist, and
her underwear removed. When she awoke Nygard was sodomizing her. She screamed and began
167
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 168 of 270
719. After Nygard finished, Jane Doe No. 13 went to the bathroom to clean herself up.
She went out to the main room and asked the modeling manager if they could leave. They left
shortly thereafter.
720. The modeling manager took Jane Doe No. 13 back to his apartment. He offered
721. In the middle of the night, she awoke to the modeling manager groping her. Jane
Doe No. 13 pleaded for him to let her sleep because she did not feel well. He let Jane Doe No. 13
go back to sleep.
722. In the morning Jane Doe No. 13 gathered her belongings and left as soon as she
could.
723. As she was leaving, she saw another young girl going up to the modeling manager’s
apartment.
726. Jane Doe No. 14 was recruited for a potential job opening in New York City with
727. In approximately 2003, Jane Doe No. 14 went to the Toronto office for the job
728. Upon arrival at the corporate office, Jane Doe No. 14 saw women and/or models
168
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 169 of 270
729. She waited several hours for Nygard and one of Nygard’s employees or
“girlfriends” talked to her and encouraged her to keep waiting. She offered her a soda while she
730. Jane Doe No. 14 drank the soda before her “interview” with Nygard.
731. Nygard arrived and the woman who provided the soda quickly left.
733. Jane Doe No. 14 asked Nygard to use the bathroom. Nygard escorted Jane Doe
734. Nygard closed and locked the door to the bedroom. He pushed Jane Doe No. 14
735. Jane Doe No. 14 cried throughout the entire rape. She was unable to move her arms
or legs.
736. Jane Doe No. 14 blacked out shortly after the rape. She awoke in a basement on a
mat with three other girls, one of whom was the girl that gave her the drugged soda.
737. Jane Doe No. 14 was eventually let out because she appeared calm and did not
claim to be raped. The “girlfriend” told her that she got the job in New York City and would need
738. Jane Doe No. 14 flew on the N-Force corporate jet to New York City with Nygard
739. Upon arrival, Nygard reserved rooms at the W Hotel in Times Square. Jane Doe
No. 14 had friends in New York. She was able to sneak out of the hotel and stay with friends to
169
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 170 of 270
740. Jane Doe No. 14 called the Nygard Companies travel office and demanded a ticket
home. She was told that they don’t buy flights home, but eventually agreed to buy her return flight
742. Jane Doe No. 15 was an acquaintance of Nygard’s niece, Angela Dyborn, and his
743. In the late 1980’s, Jane Doe No. 15 was in Los Angeles meeting with modeling
744. Angela invited her to stay at the executive suites across from Nygard’s Marina Del
Rey residence. Jane Doe No. 15 had her own private room.
745. During her stay, she met Nygard only once for a brief period.
746. In 1993, Angela told Jane Doe No. 15 that Nygard wanted her to model the Nygard
747. Nygard called Jane Doe No. 15 from the Bahamas and told her he wanted her to
model for the Nygard Companies. He told Jane Doe No. 15 that he wanted her to come to
Winnipeg and that his secretary would contact her with the details
748. The Nygard Companies paid for Jane Doe No. 15 to travel to Winnipeg, Canada.
749. Jane Doe No. 15 was told that she would be staying at the “executive suites” at the
Winnipeg office. She believed that it would be similar to her time staying at the “executive suites”
170
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 171 of 270
751. Angela drove Jane Doe No. 15 to the Nygard Companies’ Inkster factory where she
did some work for the Nygard Companies. Jane Doe No. 15 walked around the factory.
752. Angela took Jane Doe No. 15 to dinner and then to the Nygard Companies’ Notre
Dame factory.
755. Angela left and Jane Doe No. 15 quickly realized that she was staying at Nygard’s
personal apartment, which was attached to the warehouse—not a separate “executive suite.”.
756. When she arrived at the apartment, Nygard locked the door. Nygard kept the key
758. Jane Doe No. 15 was held against her will at the apartment for approximately three
days.
759. Jane Doe No. 15 believes she was drugged because she has little memory of
760. Jane Doe No. 15 was raped at least once and was sexually assaulted repeatedly.
761. Jane Doe No. 15 begged Nygard to let her go, but he stated that he could not trust
her to not tell anyone. Jane Doe No. 15 was afraid that Nygard would kill her.
762. During this time, on at least one occasion, a Nygard Companies employee brought
food and beverages to the room. Nygard was naked when he arrived and he left without assisting
Jane Doe No.15, even though she did her best to non-verbally ask for help.
763. On the third day, Nygard fell asleep. Jane Doe No. 15 attempted to call her parents,
171
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 172 of 270
764. Jane Doe No. 15 then called Nygard’s nephew, Kris Nichol, and told him where
she was.
765. Kris Nichol told Jane Doe No. 15 that he would come get her.
766. As Jane Doe No. 15 waited, she found the key to the locked door was left in the
door lock.
767. Jane Doe No. 15 fled the apartment. She was naked except for a coat that she was
768. Jane Doe No. 15 ran through the warehouse to an emergency exit, but the door was
chained.
769. A security guard for the Nygard Companies arrived and told Jane Doe No. 15 that
770. Jane Doe No. 15 lied and told the security guard that she had Nygard’s permission
to leave and threatened to have him fired if he did not let her leave.
771. The security guard let Jane Doe No. 15 leave the warehouse. She waited outside in
773. Jane Doe No. 15 wanted to call the Winnipeg police, but Kris Nichol told her that
she could not call the police because Nygard “owns” them.
774. Jane Doe No. 15 flew back to her home in Vancouver. She was terrified that
Nygard would have her killed and/or would destroy her modeling career.
775. Jane Doe No. 16 is a Canadian citizen who resides near Seattle, Washington.
172
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 173 of 270
776. During the summer of 1998, Jane Doe No. 16 was nineteen years old and was
777. Jane Doe No. 16 met Nygard through her tennis coach, who called him “Boss.”
778. Jane Doe No. 16 was invited to Nygard Cay to play tennis with Nygard on three
occasions.
779. On the second occasion, Jane Doe No. 16’s tennis coach left her alone with Nygard.
780. Nygard told Jane Doe No. 16 that he wanted her to sit next to him at dinner that
night. She stayed for dinner with Nygard and his children.
781. On the third occasion, Nygard instructed Jane Doe No. 16 to bring her travel bags
with her.
782. When she arrived at Nygard Cay, Nygard told her that he had a private cabana for
her to stay in. He escorted her to her room and told her she was welcome to stay for as long as she
wanted.
783. During one evening, Jane Doe No. 16 was in the “grotto” at Nygard Cay with
784. Jane Doe No. 16 was drugged, raped, and sodomized by Nygard. Nygard then
provided Jane Doe No. 16 to his friends for them to have sex with as well.
785. Nygard threw money at Jane Doe No. 16 after they were done.
786. Nygard was extremely verbally abusive and attacked Jane Doe No. 16’s weight and
age.
787. Nygard’s rape and sodomy caused Jane Doe No. 16 to bleed and have pain in her
173
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 174 of 270
790. In 1999, Jane Doe No. 17 was nineteen years old and was working as a waitress in
791. Jane Doe No. 17’s friend met Nygard who invited them to dinner at Nygard’s
792. They decided to attend because they were told that there would be various
793. When they arrived, Nygard was playing his own episode of “Lifestyles of the Rich
794. Jane Doe No. 17 had one and a half glasses of wine at the dinner.
795. She began to feel sick so she went upstairs to lay down in a bedroom that she found.
796. Nygard followed her upstairs. Nygard stated several comments about Jane Doe No.
17’s physical appearance, such as that she was “so pretty and black,” she looked “so young,” and
798. Jane Doe No. 17 tried to resist but was unable to because she was drugged.
799. After Nygard finished, he told her she “did a good job.”
801. The next day, Jane Doe No. 17 confronted Nygard with what he had done to her.
In response, Nygard offered her a free massage, nail treatment, and strawberries. He told her that
174
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 175 of 270
802. Jane Doe No. 18 is a United States Citizen who resides in New York.
803. In 1977, Jane Doe No. 18 was nineteen years old and was attending a University in
Montreal, Canada for the summer semester. This was the first time she had traveled outside of the
United States.
804. Jane Doe No. 18 was flying from her home back to school in Montreal.
805. She noticed a man sitting several rows in front of her on the plane continuously
806. When Jane Doe No. 18 got off the plane, she headed to baggage claim. The man
approached her while she waited for her bag and introduced himself as Nygard.
807. Nygard offered Jane Doe No. 18 a ride from his business associate to her dormitory.
808. While in the car driven by the Nygard Companies’ business associate, Nygard told
Jane Doe No. 18 about lavish parties that he attended and famous people he knew and told her that
809. During the drive, Nygard stopped at his apartment to drop off his luggage.
810. When they arrived at the apartment, Nygard invited Jane Doe No. 18 to come up
811. When they entered the apartment Nygard told her to look around and left the room.
812. As she was looking around the apartment, she turned around and Nygard was
813. Nygard attacked Jane Doe No. 18 and threw her on the bed.
814. Jane Doe No. 18 screamed for help and Nygard said, “you can scream all you want,
175
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 176 of 270
815. Jane Doe No. 18 had her menstrual period that day. Nygard ripped her pants off,
816. Jane Doe No. 18 continued to plead with Nygard to stop. She had no course of self-
defense since Nygard was well over six feet tall and Jane Doe No. 18 was 5’2” and weighed 105
pounds.
817. Nygard stated “it’s not a matter of wanting to, it’s a matter of competition, and I’m
going to win.”
818. After he was done, Nygard acted like nothing happened. He instructed Jane Doe
819. Jane Doe No. 18 was terrified. She did as she was told.
820. While in the kitchen, Jane Doe No. 18 called the only friend she knew who she had
met during summer class. She told him that she had no idea where she was and that if she wasn’t
back at the dorm within 45 minutes to call the police. She told her friend to meet her at her
dormitory.
821. After she brought Nygard his orange juice, he offered to take her home.
822. Jane Doe No. 18 was scared and did not know where she was so she accepted
823. Nygard said to Jane Doe No. 18 “now I owe you, whatever you want you can have,
a watch, or jewelry, whatever you want.” She told Nygard that she did not want anything and she
824. Nygard dropped her off and she flew home to New York the same day to see a
176
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 177 of 270
826. Jane Doe No. 18 finished the summer semester in Montreal living in fear that
Nygard would come after her and hurt and rape her again.
827. For months after the rape, Jane Doe No. 18 had nightmares and would see Nygard’s
828. Nygard’s rape has haunted Jane Doe No. 18 for 42 years.
830. In approximately 2004-2005, Jane Doe No. 19 was sixteen years old.
831. Jane Doe No. 19 was dating an older man at the time.
832. The boyfriend invited Jane Doe No. 19 to a party in Toronto at the Nygard
Companies’ offices.
833. When Jane Doe No. 19 and her boyfriend arrived at the party it was just Nygard
834. Nygard told Jane Doe No. 19 that she was beautiful and that she could be a model.
He told her that he had a plane and could fly her anywhere.
835. Nygard offered Jane Doe No. 19 and the others a “tour” of the office building.
836. Nygard eventually led them into a room with a large bed in it.
837. Nygard poured Jane Doe No. 19 a drink. Shortly thereafter, she began to feel foggy
838. Jane Doe No. 19 and the others were sitting on the bed when her boyfriend told
839. When she did not listen, her boyfriend and Nygard forcefully pulled off her
177
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 178 of 270
841. Despite her resistance, Nygard performed oral sex on Jane Doe No. 19 while the
843. After Nygard was finished, Jane Doe No. 19 went to the bathroom and began
844. Jane Doe No. 20 met Nygard in approximately 1995 when she was 20 years old.
845. Nygard’s assistant called Jane Doe No. 20 and told her that Nygard had seen a
picture of her.
846. Nygard called her one day, told her she was beautiful, and invited her to
847. Jane Doe No. 20 went to Defendants’ Toronto office and met with Nygard. He told
her she was beautiful, showed her various fabric samples, and discussed modeling jobs with her.
848. A few days later, Nygard called and informed her that he was going to the Bahamas
and that his assistant would call her with a modeling job.
849. Jane Doe No. 20 was flown from Canada to the Bahamas by the Nygard
Companies.
850. When she arrived at Nygard Cay, a worker told Jane Doe No. 20 that Nygard would
help her with her luggage and show her to her room.
851. Nygard took her to some cabins where she stayed for the first night at Nygard Cay.
852. Jane Doe No. 20 stayed at Nygard Cay for approximately one to two weeks.
178
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 179 of 270
853. Nygard entered her room without permission on several occasions and forcibly
raped, sodomized, and used an object to penetrate Jane Doe No. 20.
854. Nygard continued to promise Jane Doe No. 20 that they would discuss modeling
855. Nygard instructed Jane Doe No. 20 to bring fabric samples with her to the Bahamas
and would lure her up to his office under the guise of discussing modeling. He would then begin
raping Jane Doe No. 20 in his office and his bedroom nearby.
856. He raped Jane Doe No. 20 repeatedly with his penis and an object during her stay
at Nygard Cay.
857. Jane Doe No. 20 told a Nygard Companies’ employee who was working for Nygard
that she wanted to leave, and the employee said there was nothing she could do.
858. Jane Doe No. 20 asked Nygard to leave and he told her that she was not allowed to
859. After approximately seven to ten days, Nygard allowed Jane Doe No. 20 to leave
Nygard Cay.
861. Jane Doe No. 21 met Nygard in 1988 while working as a volunteer model at a
862. Nygard told Jane Doe No. 21 that she was beautiful and that he would like her to
863. Jane Doe No. 21 indicated that she would be in California soon and Nygard invited
179
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 180 of 270
864. Jane Doe No. 21 thought that it would be a great career opportunity and she
865. Later that month, Jane Doe No. 21 traveled from Toronto to Los Angeles.
866. Jane Doe No. 21 was staying with friends who lived in Los Angeles.
867. Jane Doe No. 21 called Nygard as he had instructed her to do and he invited her to
868. Jane Doe No. 21’s friend dropped her off at Nygard’s home.
869. Nygard’s housekeeper answered the door, showed her to her room, and offered her
a “tour.”
870. Later that evening, Nygard took Jane Doe No. 21 to an opening of a clothing store
871. The next day Nygard’s housekeeper told Jane Doe No. 21 that Nygard wanted to
see her.
872. The housekeeper took Jane Doe No. 21 upstairs to Nygard’s bedroom.
873. Within minutes, Nygard attacked her, forced her onto his bed, and ripped off her
pants.
874. Jane Doe No. 21 tried to resist, but Nygard overpowered her.
875. Nygard performed oral sex on her and then raped her.
876. After Nygard was finished, Jane Doe No. 21 immediately left the room and went
to her room.
877. She took a shower and called her friend to come pick her up. Her friend indicated
180
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 181 of 270
879. Jane Doe No. 22 met Nygard in 1977 when she was twenty-seven years old.
880. Jane Doe No. 22 was on an airplane flight from Montreal, Canada to Frankfurt,
882. Nygard approached Jane Doe No. 22 as she was seated in coach and handed her a
rose that was given to first-class passengers, along with his business card. Jane Doe No. 22 smiled
883. Jane Doe No. 22 was working for a company in the textile industry and was
traveling with her boss. Jane Doe No. 22’s employer did business with the Nygard Companies.
884. Jane Doe No. 22 and her boss attended a textile trade show in Frankfurt. Jane Doe
No. 22 ran into Nygard again at the trade show. Nygard and Jane Doe No. 22 exchanged a brief
181
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 182 of 270
885. Taking a break from the trade fair, Jane Doe No. 22 stepped outside for some fresh
air, and took a seat on a bench. Nygard soon after came out the same door and sat down at an
886. Nygard and Jane Doe No. 22 began talking about business and other things. During
the conversation, they realized they would both be in London at the end of the week and Nygard
888. After dinner, Nygard rode with Jane Doe No. 22 to her hotel and then walked her
to her door. At the door, Nygard shoved her inside the hotel room and locked the door.
890. Nygard instead suddenly ripped Jane Doe No. 22’s pantyhose down to immobilize
her legs.
891. Nygard then dragged Jane Doe No. 22 to the bed, pinned Jane Doe No. 22’s legs
down with his knees, and forcibly performed oral sex on her, and then masturbated over her until
he orgasmed.
892. During the act, Jane Doe No. 22 told Nygard to stop, however he ignored her plea.
893. When he was finished, Nygard acted as if nothing happened and fell asleep.
894. An hour or two later, Nygard awoke, forcefully pinned Jane Doe No. 22 down on
her back, again forcibly performed oral sex on her, and then raped her.
895. Afterwards, he told Jane Doe No. 22 that he would call her and she told him she
182
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 183 of 270
897. In approximately 1990, Jane Doe No. 23 was a performer in the Bahamas.
898. Jane Doe No. 23 had lunch with Nygard once before.
899. After the event, Nygard offered to take Jane Doe No. 23 home.
900. On the way home Nygard drove past Jane Doe No. 23’s apartment. She asked
several times and for him to take her home, but Nygard kept driving.
902. When they entered the property, the gate was locked behind them.
903. Nygard ordered Jane Doe No. 23 to change out of her dress and change into a
skimpy outfit. At first, she told him “no,” but he insisted, so she complied.
904. Nygard took her outside to a gazebo and forced Jane Doe No. 23 to give him oral
sex.
905. Nygard then took her inside to the bedroom. He shoved her on the bed and tried to
penetrate her.
906. Jane Doe No. 23 attempted to resist while Nygard overpowered her.
908. Nygard got furious and rolled off of her. Jane Doe No. 23 cowered near the side of
the bed and asked him to take her home. Nygard did not respond but he was clearly enraged and
909. About ten minutes later she timidly asked Nygard again to take her home. Nygard
refused.
910. Finally, Nygard got up off the bed and was still furious. He motioned to Jane Doe
183
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 184 of 270
911. Jane Doe No. 23 was still wearing the skimpy outfit that Nygard made her put on.
She quickly changed into her clothes and followed Nygard to his car. He drove her home.
912. During the drive, Nygard was still furious and drove extremely fast along the dark
and windy road, despite Jane Doe No. 23’s pleas for him to slow down. Jane Doe No. 23 was
extremely frightened.
913. The next day Nygard called Jane Doe No. 23 and acted as if nothing happened.
914. Jane Doe No. 24 is a United States citizen who resides in Tennessee.
915. In 1989, Jane Doe No. 24 was nineteen years old and recently began a new job as
916. Nygard was a passenger on Jane Doe No. 24’s first flight, which was a flight from
917. Jane Doe No. 24 talked with Nygard on the flight and they exchanged phone
numbers.
918. Nygard contacted Jane Doe No. 24 and invited her to his Marina Del Rey home.
919. When Jane Doe No. 24 arrived, a girl greeted her and gave her a marketing packet
for the Nygard Companies to read while she waited for Nygard to come downstairs.
920. Nygard came down and gave Jane Doe No. 24 a “tour” of the house.
922. Nygard offered Jane Doe No. 24 some white wine and she accepted.
923. Nygard then became aggressive and porn came on the TV screens in the bedroom.
184
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 185 of 270
925. Afterwards, Jane Doe No. 24 tried to leave. She made it outside, but could not get
926. A car then pulled in through the gate and she ran out of the compound.
927. Nygard attempted to contact Jane Doe No. 24 afterwards and invite her to Nygard
Cay.
930. In 1995, Jane Doe No. 25 was living in Los Angeles, California and was working
as a model.
931. Jane Doe No. 25 met Nygard at a club in Hollywood. Nygard cornered her and
932. Nygard told Jane Doe No. 25 that he had his eye on her for a while and wanted her
933. Nygard asked Jane Doe No. 25 to go to lunch with him the next day and she agreed.
934. At lunch, Nygard invited Jane Doe No. 25 to come with him to Nygard Cay.
935. Jane Doe No. 25 told him she did not feel comfortable traveling with him alone.
936. Jane Doe No. 25 invited two of her friends and they flew down to Nygard Cay with
937. When they arrived at Nygard Cay, Nygard’s personality began to change.
938. Nygard would not leave Jane Doe No. 25 and her friends alone and would not allow
185
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 186 of 270
939. Nygard also began making sexual advances toward Jane Doe No. 25.
940. Jane Doe No. 25 and her friends tried to leave the compound to go sightseeing one
day and the Nygard Companies’ employee who was working the gate, Pam Erickson, would not
941. Jane Doe No. 25 and her friends began to feel very uncomfortable and like they
942. One night, Jane Doe No. 25 and her friends were able to escape the compound, but
they did not have their clothes or passports with them so they had to return.
943. When Nygard found out that they had left the compound without his permission,
he was furious.
944. Nygard screamed at Jane Doe No. 25 and her friends and sent them home the next
945. Later that year, Jane Doe No. 25 attended a “pamper party” at Nygard’s Marina Del
Rey home.
946. She felt that because she went with friends and there were many other people there
947. Towards the end of the night Jane Doe No. 25 was upstairs in a room with Nygard
949. Jane Doe No. 25 tried to leave the room but could not get out.
950. Jane Doe No. 25 was given a drink while upstairs and suddenly began to feel very
fuzzy.
951. Nygard forced Jane Doe No. 25 down on the bed and sodomized her.
186
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 187 of 270
952. Each time he thrusted, she vomited. Afterwards, Nygard allowed Jane Doe No. 25
to leave.
953. Jane Doe No. 25 did not tell anyone what happened to her because Nygard was
very influential in Los Angeles at the time and she was worried that he would ruin her modeling
956. Jane Doe No. 26 met Nygard through a mutual friend who told her that Nygard was
957. Nygard came to Jane Doe No. 26’s apartment and approved her for modeling work
958. Nygard offered Jane Doe No. 26 a high paying job as a model for the Nygard
Companies.
959. Nygard told Jane Doe No. 26 that he wanted her to travel with him to the Bahamas
960. Jane Doe No. 26 flew to Nassau, the Bahamas with Nygard from Toronto on a
961. Nygard’s personality began to change after they arrived at Nygard Cay. He became
962. Jane Doe No. 26 was given her own room, but was not allowed to leave the
187
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 188 of 270
963. By this time, Jane Doe No. 26 was terrified of Nygard and did whatever he told her
to do.
964. Nygard violently raped Jane Doe No. 26 on multiple occasions during her stay at
Nygard Cay.
965. Jane Doe No. 26 was eventually driven to the airport by an employee of the Nygard
Pam
Erickson
188
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 189 of 270
967. In approximately 1980, Jane Doe No. 27 was working as a model for a modeling
agency.
968. The modeling agency selected Jane Doe No. 27 to go to Los Angeles for a beauty
pageant.
969. Jane Doe No. 27 was seeking a sponsorship to help pay for the trip.
970. Jane Doe No. 27’s mother drove her to Defendants’ Winnipeg office to meet with
971. Jane Doe No. 27 met with Nygard in his office while her mother waited outside.
972. Jane Doe No. 27 handed Nygard her modeling portfolio and Nygard indicated that
he thought she was beautiful. While looking at the portfolio, he said “nice eyes, nice lips.”
973. Nygard asked Jane Doe No. 27 to travel the world with him. She declined.
974. Nygard got up and walked over to her, grabbed her left breast, and said “cute you
must be a size 5.” Jane Doe No. 27 was shocked and told Nygard that her mother was outside
975. Jane Doe No. 27 ran outside, but no one was in the office building anymore.
976. Both the back and front doors of the building were locked.
977. Jane Doe No. 27 began to panic, but eventually found a janitor who had keys to let
978. Jane Doe No. 27’s mother drove her home. Jane Doe No. 27 told her mother what
happened but did not tell anyone else because she did not think anyone would believe her because
189
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 190 of 270
980. In approximately 2010, Jane Doe No. 28 was working as a model in California.
981. Nygard saw a picture of Jane Doe No. 28 and the Nygard Companies flew her to
982. Upon arrival, Jane Doe No. 28 took a taxi to Nygard’s home in Toronto.
983. When she arrived, Nygard was not there and some other girls showed her to her
room. Many of the girls looked very young to Jane Doe No. 28.
984. On her second day at Nygard’s home, Jane Doe No. 28 wanted to explore Toronto,
but Nygard’s security guards would not let her leave the premises.
985. Jane Doe No. 28 began to realize that the girls that were staying at Nygard’s home
seemed scared.
986. Employees of the Nygard Companies were collecting the girls’ passports so they
987. Jane Doe No. 28 pretended that she could not find her passport when they requested
it.
988. Jane Doe No. 28 was forced to go out at night with Nygard.
990. On the second day at the house, Jane Doe No. 28 was in the bathroom at Nygard’s
991. Nygard followed into her bedroom and forced himself on Jane Doe No. 28. She
tried to push him away and he forcefully sodomized her, which was very painful.
993. A few days later, Jane Doe No. 28 was flown to New York City with Nygard and
all the other girls at the house. Jane Doe No. 28 was able to escape the once she got to New York.
190
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 191 of 270
995. In approximately 1997, Jane Doe No. 29 was in the Bahamas modeling for a
996. One night, Jane Doe No. 29 was at a casino with the other models and her sponsor.
998. Jane Doe No. 29’s sponsor told her that Nygard was an influential fashion designed.
999. Nygard invited Jane Doe No. 29 to come to Nygard Cay to discuss modeling for
1001. A Nygard Companies’ driver picked Jane Doe No. 29 up and drove her to Nygard
Cay.
1002. When Jane Doe No. 29 arrived, Nygard was not there so she waited in a waiting
area.
1003. A Nygard Companies’ employee took Jane Doe No. 29 to a bungalow to get a
1004. Afterwards, Nygard came down and they had a brief conversation about modeling
1005. Nygard told Jane Doe No. 29 that he wanted her to model for Defendants’ fashion
line and that he wanted to use her body to design new clothes.
1006. Nygard’s driver took Jane Doe No. 29 back to her hotel and she later flew home to
191
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 192 of 270
1007. Approximately two months later, Nygard called Jane Doe No. 29 and told her he
had some modeling work for her to do for the Nygard Companies.
1008. Jane Doe No. 29 booked travel arrangements through the Nygard Companies and a
1009. The driver took Jane Doe 29 to Nygard Cay and put her bags in Nygard’s bedroom.
1010. Jane Doe No. 29 went to dinner with Nygard and others that night.
1011. After dinner, she went to Nygard’s room to get her things. She told Nygard that
1012. Nygard became offended and aggressive and started making sexual advances.
1013. The next morning, she moved her things to another room at Nygard Cay.
1014. Jane Doe No. 29 stayed at Nygard Cay for approximately one week. During that
time period, Nygard entered Jane Doe No. 29’s room without permission on numerous occasions
1016. A month later, Nygard called Jane Doe No. 29 and apologized. He convinced her
to travel to his Marina Del Rey property for a modeling job. The Nygard Companies paid for Jane
1017. Nygard raped Jane Doe No. 29 while at his Marina Del Rey residence and forced
Jane Doe No. 29 to have sex with him and other women.
1018. Jane Doe No. 29 confronted Nygard and told her that she wanted to leave, but she
had no money.
1019. Nygard left $700 in U.S. currency for her in the door and she left.
192
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 193 of 270
1020. Approximately one month later, Nygard called Jane Doe No. 29 and asked for her
to come to Nygard Cay. He told her that he had a famous photographer working there and he
would be doing photo shoots. He told her that she would get paid for the photo shoot and other
girls would be there with her, which made her feel safer.
1021. When Jane Doe No. 29 arrived at Nygard Cay, there was a photographer there, but
1022. Jane Doe No. 29 spoke to one of the other girls there and discovered that Nygard
1023. During her stay there, Nygard once again raped Jane Doe No. 29 on multiple
occasions and also forced her to engage in sexual activity with other girls.
1024. Jane Doe No. 30 is a British citizen who resides in the United Kingdom.
1025. In approximately 2000, Jane Doe No. 30 was living in Los Angeles and working as
1026. Jane Doe No. 30 met Nygard through a client who was a model.
1027. Nygard invited Jane Doe No. 30 to “pamper parties” at his Marina Del Rey home.
1029. During one of the “pamper parties,” Jane Doe No. 30 drank some champagne and
1030. Jane Doe No. 30 was upstairs with others near the hot tub.
1031. There was a massage room set up nearby and Jane Doe No. 30 got a massage.
1032. After the massage, she went to change into her clothes in a bedroom that was used
193
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 194 of 270
1033. When Jane Doe No. 30 came out of the bathroom, the bedroom door had been slid
shut.
1034. Nygard was standing in the room. He pulled-down his pants, began lubricating
1035. He pushed Jane Doe No. 30 onto the bed on all fours and attempted to sodomize
1037. Jane Doe No. 31’s daughter was friends with one of Nygard’s children.
1038. In 1998, Nygard called Jane Doe No. 31 and invited her and her children to come
stay at Nygard Cay in exchange for a favor she had done for Nygard’s child.
1039. Nygard also knew that Jane Doe No. 31 was an artist. He told Jane Doe No. 31 that
he wanted to discuss potential art and design opportunities with her for the Nygard Companies at
Nygard Cay.
1040. While at Nygard Cay, Nygard invited Jane Doe No. 31 to his room under the guise
of discussing artwork and design since Jane Doe No. 31 is an artist. He told Jane Doe No. 31 that
he wanted her to discuss some of the artwork and décor around the Nygard Cay property and get
1041. When she entered his room, Nygard was already seated on the bed and motioned
194
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 195 of 270
1043. Nygard suddenly grabbed Jane Doe No. 31’s hand and began to lead her to his
bathroom. Jane Doe No. 31 went with him, believing he was going to show her a piece of art and
1045. Nygard then grabbed her head in his hands and began moving her head back and
forth to force her to give him oral sex. The force and thrust were great enough that Jane Doe No.
1046. Jane Doe No. 31 was afraid he could snap her neck and was attempting to pry his
hands loose.
1049. There were two News Years Eve events that Jane Doe No. 31 was required to go to
1050. Jane Doe No. 31 was also required to attend dinner every single night. Nygard’s
guests were only able to eat dinner if they joined him at the table and she had to be in his presence
in order to eat.
1051. While at Nygard Cay, Jane Doe No. 31 saw multiple girls that appeared very young.
1053. In 2009, Jane Doe No. 32 was brought to Nygard Cay to a model in a bikini photo
shoot.
1054. Jane Doe No. 32 stayed at Nygard Cay for three or four nights.
195
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 196 of 270
1055. During her stay, Nygard invited Jane Doe No. 32 for dinner in a private area and
then invited her and other guests for dancing and drinks.
1056. Jane Doe No. 32 also met some of Nygard’s “girlfriends” who were living at
Nygard Cay.
1057. Nygard’s “girlfriends” were very friendly and invited Jane Doe No. 32 for drinks
in a cabana hut.
1058. Jane Doe No. 32 was provided cocaine and pressured to take it by Nygard’s
1059. Nygard’s “girlfriends” told Jane Doe No. 32 that they were all paid by Nygard for
1060. Nygard then entered the room with other men who were his bodyguards.
1061. Nygard began to touch Jane Doe No. 32’s legs and vaginal area and offered her
1062. She looked at the other girls and they looked scared and worried.
1063. Jane Doe No. 32 turned Nygard down. Nygard appeared frustrated and annoyed.
1064. Nygard then left with bodyguards while Jane Doe No. 32 went to use the bathroom.
1065. When she returned, the “girlfriends” gave her another drink.
1066. Nygard’s “girlfriends” spiked one of Jane Doe No. 32’s drinks with drugs.
1067. Jane Doe No. 32 blacked out shortly thereafter, even though she did not over-drink
1068. Nygard raped, sexually assaulted, or sexually battered Jane Doe No. 32.
1069. Jane Doe No. 32 woke-up in the early morning and recalls walking back to her own
hut, even though she was having trouble moving her legs.
196
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 197 of 270
1070. Jane Doe No. 32 left Nygard Cay pursuant to her previously booked plane ticket.
1072. In 2009, Jane Doe No. 33 was twenty-three years old and was working as a model.
1073. Jane Doe No. 33 was invited to Nygard Cay to audition for a modeling job with the
1074. The Nygard Companies flew Jane Doe No. 33 to Nygard Cay.
1075. While at Nygard Cay, Nygard coerced Jane Doe No. 33 to have sex with him in
1076. Nygard told her that if she did not have sex with him, she would not receive a
modeling contract.
1077. Nygard also attempted to coerce Jane Doe No. 33 to “recruit” others for Nygard to
1080. Jane Doe No. 34’s manager took her to Nygard Cay for a photo shoot.
1081. Jane Doe No. 34 stayed at Nygard Cay for one week.
1082. Jane Doe No. 34 met Nygard while staying at Nygard Cay. Nygard bragged about
his “girlfriends” and their glamourous lifestyles and made sexually suggestive comments to Jane
1083. Jane Doe No. 34 had a bad feeling and asked her male friend to sleep in her room
197
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 198 of 270
1084. In the middle of the night, Nygard entered her room. He became visibly flustered
when he saw the other man in the room and stated an excuse about looking for something before
abruptly leaving.
1085. One year later, in approximately 2009, Jane Doe No. 34’s manager forced her to
return to Nygard Cay. She went with her boyfriend for a party.
1086. While at Nygard Cay, Jane Doe No. 34 went to the bathroom. She did not know
1087. As Jane Doe No. 34 entered the bathroom, Nygard quickly shut and locked the
door.
1088. Jane Doe No. 34’s boyfriend saw that Nygard was in the bathroom and began
1090. Nygard stuck his hand in Jane Doe No. 34’s urine stream while she urinated.
1092. In 1986, Jane Doe No. 35 was working as a model for the Nygard Companies. She
modeled the Nygard Companies’ winter clothing line at the Hyatt Regency Hotel in Vancouver,
Canada.
1093. After the show, Nygard invited Jane Doe No. 35 to come to an “after-show party”
for champagne and strawberries in the penthouse of the Hyatt Regency Hotel.
1094. When Jane Doe No. 35 arrived at the hotel room, however, there was no party and
Nygard was the only one there. Jane Doe No. 35 quickly left the room.
198
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 199 of 270
1095. In 1987, approximately five months later, Nygard called Jane Doe No. 35 and
offered her a paid trip to the Bahamas for snorkeling, swimming, dinners, and other amenities.
1096. Jane Doe No. 35 asked Nygard where she would be staying. Nygard told her that
she would stay at the guest house. Jane Doe No. 35 decided to go because she believed she would
1097. Jane Doe No. 35 was picked-up at the airport by a male employee of Defendants
who lived in an anchored boat off coast of Lyford Cay. The man offered her alcohol throughout
1098. When she arrived, she noticed that there was no guest house located at Lyford Cay,
1099. When Jane Doe No. 35 asked if she could stay at the guest house several miles
away, Nygard told her that she could not because his parents were staying there. Jane Doe No. 35
reminded Nygard that they established over the phone that she would be staying at the guest house.
1100. The first day, Jane Doe No. 35 was left to herself while Nygard oversaw
1101. After sunset, Nygard stripped down in a lit area and showered outside naked for
1102. Later that night, Jane Doe No. 35 was pretending to sleep on a couch in the living
room so Nygard would leave her alone. Nygard told her she could not sleep there.
1103. Nygard forced Jane Doe No. 35 to his bedroom. He began making sexual demands,
forced Jane Doe No. 35 to perform oral sex on him, and then raped her.
1104. Jane Doe No. 35 pleaded with Nygard to leave her alone.
199
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 200 of 270
1105. He told Jane Doe No. 35 that she owed him for paying to fly her down to the
1106. The next day, Jane Doe No. 35 ate lunch with Nygard and others.
1107. Nygard told Jane Doe No. 35 that he regularly played tennis with the chief of police.
Nygard also told her that he paid a lot of money to the Bahamian police and was trying to get the
name of Lyford Cay changed to Nygard Point. Jane Doe No. 35 did not tell anyone what happened
1108. Later that night, Jane Doe No. 35’s bag was loaded into a Nygard Companies’ Jeep
and she was told by the same employee who picked her up from the airport that she was permitted
to leave now. He told her that he had orders to take her somewhere.
1109. Jane Doe No. 35 was not told where they were going.
1110. The employee dropped Jane Doe No. 35 off in the middle of nowhere. She walked
1111. Jane Doe No. 35 waited on the side of the road in the dark for hours until a bus
finally arrived.
1112. She took the bus to a Catholic Church in Nassau. The priest charged her $40 to let
1113. The next day Jane Doe No. 35 found a hostel to stay at for the remaining seven days
200
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 201 of 270
1115. In approximately 1988 or 1989, when she was twenty-eight years old, Jane Doe No.
36 met Nygard at the airport in the Bahamas while she was waiting for a flight to Toronto, Canada.
1116. Jane Doe No. 36 was traveling with a male friend of hers.
1117. Nygard’s assistant approached Jane Doe No. 36 and invited her to sit in first-class.
Jane Doe No. 36 declined. After the plane landed, Nygard approached Jane Doe No. 36 and
1118. Nygard attempted to impress Jane Doe No. 36 and told her that he owned the
Nygard Companies and was an influential fashion designer. He also told her that he was friends
with the Canadian Prime Minister and was the father of the Free Trade Agreement.
1119. Nygard insisted that the driver take Jane Doe No. 36 past the Nygard Companies’
Toronto office building so that Jane Doe No. 36 could see it.
1120. A few weeks later, Nygard invited Jane Doe No. 36 to dinner. At dinner, Nygard
continued to boast about his wealth and influence in the fashion industry.
1121. Several months later, Nygard called Jane Doe No. 36 and invited her to a concert.
1122. After the show, the Nygard Companies’ driver was driving Jane Doe No. 36 and
Nygard home when Nygard invited Jane Doe No. 36 for a drink.
1123. Nygard took Jane Doe No. 36 to the Nygard Companies office building in Toronto.
He brought Jane Doe No. 36 to a hidden living space in the Nygard Companies’ office.
1124. In order to enter and exit the room, there was keypad with a code.
1125. Nygard entered the key code and closed the door. There were no door handles or
knobs in the room and the only way out was by entering the key code.
201
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 202 of 270
1126. Nygard asked Jane Doe No. 36 to make him a sandwich. As she was doing so,
1127. Nygard called Jane Doe No. 36 a “tease,” ripped her clothes off, and forcefully
raped her.
1128. When he was finished, Nygard threw a $100 bill at Jane Doe No. 36. Jane Doe No.
36 told him she did not want his money and pleaded with him to let her out of the room.
1129. Nygard let Jane Doe No. 36 out and she walked through the Nygard Companies’
1130. At the exit, there was a Nygard Companies’ security guard who let Jane Doe No.
36 out.
1131. As she was leaving, Jane Doe No. 36 told the security guard that Nygard raped her.
1132. Jane Doe No. 36 was in such a hurry to leave the Nygard Companies’ office that
1133. Jane Doe No. 36 called the Nygard Companies’ office and told a secretary that she
1134. A secretary of the Nygard Companies met Jane Doe No. 36 and delivered her jacket
to her.
1135. Jane Doe No. 36 told the secretary that Nygard raped her. The secretary reacted as
1136. Jane Doe No. 36 eventually reported the rape to Toronto police.
1137. Nygard discovered that someone reported him to Toronto police for rape.
202
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 203 of 270
1138. Jane Doe No. 36 learned that Nygard’s head of security flew from Los Angeles to
1139. Jane Doe No. 36 became scared and intimidated and decided not to press charges.
1140. Jane Doe No. 37 is a Canadian citizen who resides in Los Angeles, California.
1141. Jane Doe No. 37 is from Winnipeg, Canada where Nygard lived at the time.
1142. Jane Doe No. 37’s father was in the fur business and sold Nygard furs, which he
1143. In approximately 1977, when Jane Doe No. 37 was approximately fourteen or
fifteen years old, she worked in her father’s store and frequently saw Nygard there.
1147. When Jane Doe No. 37 went to enter the bathroom, Nygard pushed her in and
1148. Nygard raped Jane Doe No. 37 in the bathroom. Jane Doe No. 37 was a virgin at
the time.
1149. Jane Doe No. 37 did not tell anyone because she was afraid, ashamed, and
embarrassed.
1150. Approximately a few years later, Jane Doe No. 37 was living in London and she
1151. Nygard sent Jane Doe No. 37 a drink from across the bar.
1152. Unknown to Jane Doe No. 37, Nygard spiked the drink with drugs.
203
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 204 of 270
1153. Jane Doe No. 37 accepted the drink, but kept her distance because she was afraid
of Nygard.
1154. Jane Doe No. 37 blacked out and woke up in a hotel room with Nygard and another
man.
1155. Nygard threatened Jane Doe No. 37. He pointed his finger at her and told her “you
1157. Jane Doe No. 38 is a United States citizen who resides in Los Angeles, California.
1158. In approximately 1994, Jane Doe No. 38 met Nygard at a party in Los Angeles.
1159. Nygard told Jane Doe No. 38 that she was beautiful and that she should model for
1160. Jane Doe No. 38 was interested in modeling and exchanged information with
Nygard.
1161. Nygard sent a Nygard Companies’ limo to pick Jane Doe No. 38 up from her
mother’s house.
1162. The limo took Jane Doe No. 38 to Nygard Marina Del Rey property.
1163. During the limo ride, videos of Nygard and the Nygard Companies
1164. After Jane Doe No. 38 arrived at the Marina Del Rey property, Nygard invited her
to go to dinner.
1165. After dinner, Nygard took Jane Doe No. 38 to a night club.
1166. Nygard spiked Jane Doe No. 38’s drink with drugs.
204
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 205 of 270
1167. During the car ride back to the Marina Del Rey property, Nygard put his hand
1169. She awoke in a bed at the Marina Del Rey property to Nygard raping her. She felt
1170. The next morning Jane Doe No. 38 was still feeling very “out of it.”
1171. Nygard gave Jane Doe No. 38 $300 in U.S. currency and told her that he wanted
her to stay for a party that he was having that night because he wanted her to meet his modeling
contacts.
1172. Jane Doe No. 38 wanted to leave, but could not get out of the house because all the
1173. Jane Doe No. 38 became very scared and called her friend to come get her.
1174. Jane Doe No. 38 was worried that her friend could not get into the party because
1175. Jane Doe No. 38’s friend arrived at the Marina Del Rey property and told the
Nygard Companies’ security employees at the gate that she was invited to the party by Jane Doe
No. 38.
1176. The security employees let Jane Doe No. 38 into the residence.
1177. When Jane Doe No. 38’s friend arrived, there were several scantily clad females
1178. Jane Doe No. 38’s friend grabbed Jane Doe No. 38, who was still feeling the effects
205
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 206 of 270
1179. They could not get out of the door because they did not have the key code to unlock
it.
1180. Jane Doe No. 38’s friend demanded the key code from the guests that were in the
room.
1181. The man told her that Nygard was the only one with the key code.
1182. Jane Doe No. 38’s friend threatened to call the police if they did not let them leave.
1183. The man went into another room and when he came back, he told Jane Doe No.
1184. Jane Doe No. 38’s friend walked into the room that the man had went to.
1185. She saw a large bed with approximately six people naked in it. Nygard was on top
1186. Jane Doe No. 38’s friend left the room and they waited for Nygard to come out of
the room.
1187. When Nygard came out, Jane Doe No. 38’s friend threatened to call the police if
Nygard did not enter the key code and let them leave.
1188. Nygard entered the key code and told Jane Doe No. 38 and her friend to leave with
disgust.
1189. Jane Doe No. 39 is a United States citizen who resides in New York.
1190. In approximately 2010-2011, Jane Doe No. 39 was walking down the street in New
York City when a woman approached her and told her about a modeling job for the Nygard
Companies’ store.
206
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 207 of 270
1191. Jane Doe No. 39 took the job and worked as a model at the Nygard Companies’
1192. The same woman called Jane Doe No. 39 and told her that Nygard wanted to meet
her.
1193. The woman offered to have a car pick Jane Doe No. 39 up and drive her to Nygard.
1194. The driver of the car offered Jane Doe No. 39 drinks on the way to meet Nygard.
1195. Jane Doe No. 39 was taken to the Nygard Companies’ corporate headquarters.
1196. Jane Doe No. 39 was taken to Nygard’s office on the sixth floor of the corporate
headquarters.
1197. Nygard invited Jane Doe No. 39 to go to dinner with him at the W Hotel. Jane Doe
No. 39 accepted.
1198. Nygard took Jane Doe No. 39 up to two adjoining rooms at the W Hotel.
1199. One of the rooms was full of other girls and young woman. Jane Doe No. 39 had
previously met one of the women who was in the room. The woman welcomed Jane Doe No. 39.
1200. Nygard arrived and told Jane Doe No. 39 to order some food to the room.
1201. Nygard led Jane Doe No. 39 into the other room.
1202. The woman that welcomed Jane Doe No. 39 said “have fun” as she closed the door.
1205. Jane Doe No. 39 thought about trying to leave, but there were security guards
1206. Nygard raped Jane Doe No. 39 by digitally penetrating her vagina.
207
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 208 of 270
1207. Jane Doe No. 39 was fearful where this was headed. She went to the bathroom and
then used the opportunity to run for the door and escape.
1208. A security guard was outside the door, but he was not able to stop her from fleeing.
1210. Jane Doe No. 40 was hired by the Nygard Companies to be a personal assistant to
Nygard.
1211. Throughout the years, Jane Doe No. 40 traveled to Defendants’ Toronto office one
1212. In approximately 2001, Nygard requested that Jane Doe No. 40 travel to Nygard
1213. The Nygard Companies paid for Jane Doe No. 40 to travel to Nygard Cay.
1214. During one evening, Jane Doe No. 40 joined Nygard and some other guests for
drinks.
1215. Nygard spiked Jane Doe No. 40’s drink with drugs.
1216. Jane Doe No. 40 began to feel ill, so she went to sleep in her room.
1217. Jane Doe No. 40 woke-up in the morning and her anus was sore.
1218. Jane Doe No. 40 had knowledge that Nygard had used drugs to sexually assault
women.
1219. Jane Doe No. 40 confronted Nygard the next morning about why her anus was sore.
1220. Nygard grabbed Jane Doe No. 40’s arm tightly and told her that if she told anyone
1221. Jane Doe No. 40 understood this as a threat that Nygard would have her killed.
208
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 209 of 270
1222. Jane Doe No. 40 got in a taxi as soon as she could and left all her belongings at
Nygard Cay.
1224. Jane Doe No. 41 is a Bahamian citizen who currently resides in the United States.
1225. Between 2004 and 2006, Jane Doe No. 41 was approximately eighteen years old,
living in the Bahamas, and was invited by a friend to a “pamper party” at Nygard Cay.
1226. Upon arrival at Nygard Cay, Jane Doe No. 41 was registered at the ComCor office
where Nygard Companies’ employees took down her contact information and photographed her.
1227. At some point during the “pamper party,” Nygard came outside to scope out all of
the female party guests and select his target. Nygard noticed Jane Doe No. 41 and instructed one
of the Nygard Companies paid “girlfriends” to bring Jane Doe No. 41 to him and introduce her.
1228. Nygard met Jane Doe No. 41 and invited her to play poker.
1229. Nygard made sexual comments to her, including, “I would like my face to be your
1230. Jane Doe No. 41 began speaking to one of Nygard’s paid “girlfriends” who
encouraged her to drink alcohol until she was somewhat “tipsy.” The drinks were served by
1231. Jane Doe No. 41 was invited on the Nygard Companies’ boat, the Lady Hilka.
1233. The “girlfriend” informed Jane Doe No. 41 that Nygard wanted to have sex with
her.
1234. Nygard then grabbed Jane Doe No. 41 and began undressing her without a word.
209
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 210 of 270
1235. Jane Doe No. 41 tried to push him away but felt incoherent and too intoxicated to
1236. Nygard then forced himself on top of Jane Doe No. 41 and raped her. She passed
out.
1237. When she awoke, she found that the “girlfriend” was in the bed with her and that
Nygard had left $500 on the bedside table as “payment” for “a good time last night,” according to
the “girlfriend.”
1238. The Nygard Companies’ ComCor employee then arranged for a driver to take Jane
1239. In 2008 or 2009, Jane Doe No. 41 began working at a local club in the Bahamas.
1240. One evening, Nygard came in with several females. At least one of these females
1241. It was apparent to Jane Doe No. 41 that Nygard did not remember raping her.
1242. As she was serving the group drinks, Nygard physically struck Jane Doe No. 41 on
1243. After he left, one if his paid “girlfriends” came back into the club and “recruited”
Jane Doe No. 41 by exchanging numbers and asking her to hang out.
1244. The “girlfriend” invited Jane Doe No. 41 to Nygard Cay for dinner and approved
1245. After attending the first dinner, Jane Doe No. 41 began attending dinners frequently
as a “filler,” which was an extra body at the table to make sure there were enough dinner guests.
1246. Approximately 2-4 years later, the same paid “girlfriend” got Jane Doe No. 41 a
job in the kitchen at Nygard Cay because Jane Doe No. 41 desperately needed employment.
210
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 211 of 270
1247. Jane Doe No. 41 began working in the kitchen and eventually started getting
1248. When Nygard first saw Jane Doe No. 41 in the role of ComCor, he again
commented on her “nice butt” and in the same conversation, referenced himself as being “a great
1249. After working there for some time, Jane Doe No. 41 was in Nygard’s room
performing her duties when Nygard touched her body inappropriately and suggested that in order
to get the overtime she had earned or the raise she was entitled to, she would have to engage in
1250. Nygard threatened to terminate her employment or withhold her wages if she
1251. Jane Doe No. 41, having no other employment options and being the sold
1252. She unwillingly and through coercion engaged in a commercial sex act with Nygard
under the fear of losing her job and not being able to provide for her child.
1253. Nygard began raping Jane Doe No. 41 on a frequent basis while at Nygard Cay and
1254. Knowing her financial need, Nygard also threatened Jane Doe No. 41 to force her
to introduce other women to him. Nygard’s directive was, “the younger, the better.”
1255. In approximately 2014, Jane Doe No. 41 began traveling with Nygard.
1256. Jane Doe No. 41 flew with Nygard to New York City, Los Angeles, Ft. Lauderdale,
211
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 212 of 270
1257. During these trips, Nygard confiscated her passport and withheld cash from her so
1258. While travelling within the United States, Nygard repeatedly raped Jane Doe No.
1259. While in New York City, Nygard raped Jane Doe No. 41 on more than one
occasion.
1260. During one of the rapes in New York City, Nygard forcibly penetrated Jane Doe
No. 41’s anus with his finger to remove her stool and consume it.
1261. In New York City, Jane Doe No. 41 was coerced to engage in “orgies” and invite
other women to participate with Nygard in the “orgies.” Jane Doe No. 41 was often forced to have
sex with multiple partners in a night so that Nygard was able to engage in sexual acts with their
female partners.
1262. Nygard required Jane Doe No. 41 to attend the “swingers club” with Nygard in
New York City and was driven to the club by the Nygard Companies’ driver. Jane Doe No. 41
was supposed to bring the lube and was kicked out by Nygard when she forgot it. Jane Doe No.
41 had to stand in the freezing cold for hours waiting for Nygard.
1263. While they traveled, Nygard controlled what Jane Doe No. 41 ate, how much she
exercised, what she wore, and what she did to serve him. He forced her to see plastic surgeons
about liposuction and breast augmentation, although she managed to evade those procedures.
1264. Sometime between 2014 – 2015, Nygard raped Jane Doe No. 41while they were
staying at the W Hotel in Ft. Lauderdale, Florida. Nygard told her, “if you are here, you have to
do this.”
212
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 213 of 270
1265. Nygard sent Jane Doe No. 41 to retrieve cash out of his safe when he had important
political contacts over for dinner, or when he needed to pay someone for a sexual act.
1266. Jane Doe No. 41 witnessed Nygard use this money, paid by the Nygard Companies,
to bribe Bahamian public officials, politicians, or high-ranking police officers. On other occasions,
Jane Doe No. 41 witnessed Nygard offer public officials, politicians, or high-ranking police
1267. In 2015, Jane Doe No. 41 left Nygard’s employment after being suspended by
Nygard.
1268. Fearing for her safety in the Bahamas due to Nygard’s threats, relationships with
known hitmen, and bribes and relationships with politicians and law enforcement, she
1269. Jane Doe No. 42 is a Canadian citizen who resides in Los Angeles, California.
1270. In approximately 1992, Jane Doe No. 42 was working as a model in Toronto.
1271. Jane Doe No. 42’s friend told her about a modeling opportunity in California and
1272. The “model house” was actually a run-down apartment across from Nygard’s
1273. There were approximately four to six young women living at the “model house.”
1274. Once per week Nygard gave Jane Doe No. 42 and the other women $100 to
accompany him to a night club and surround him while he was there.
1275. Jane Doe No. 42 and the other young women had to live off the $100 per week that
213
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 214 of 270
1276. Jane Doe No. 42 lived at the “model house” for approximately two months.
1277. While she was there, neither Jane Doe No. 42 nor any of the other young women
did any modeling jobs for the Nygard Companies, as they were promised.
1278. Jane Doe No. 42 got sick with meningitis while she was at the “model house” so
1279. Jane Doe No. 42 believed that she had blown her modeling opportunity with the
Nygard Companies.
1280. Nygard, however, eventually contacted Jane Doe No. 42 and told her that the
Nygard Companies had a new clothing line coming out that he wanted her to model.
1281. Nygard invited Jane Doe No. 42 to the Nygard Companies’ office in Toronto.
1282. While at the office, Jane Doe No. 42 tried on some clothing items for Nygard.
1283. Afterwards, Nygard offered Jane Doe No. 42 a “tour” of the office and showroom.
1284. Jane Doe No. 42 believed that she was being hired as a model for the Nygard
1285. At the end of the “tour,” Nygard led Jane Doe No. 42 into a dark room with a hidden
1286. Jane Doe No. 42 became very scared. She began frantically searching for a door
1287. A short time later, some dim lighting came on. To Jane Doe No. 42’s horror,
Nygard was standing in the room naked and there was a large bed in the middle of the room.
1288. Nygard pushed Jane Doe No. 42’s face down on the bed and sodomized her.
1289. After the rape, Nygard put on a robe and acted as if nothing had happened.
214
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 215 of 270
1290. Jane Doe No. 42 was extremely frightened and pleaded with Nygard to let her out
of the room.
1291. Nygard opened up the door by punching in a key code and let her out.
1292. Jane Doe No. 42 ran out of the Nygard Companies’ office as quickly as she could.
1293. Jane Doe No. 42 bled from her anus for the next several days after the rape.
1294. Jane Doe No. 42 did not report the rape because she was afraid.
1295. Nygard contacted Jane Doe No. 42 after the rape and invited her for dinner.
1296. Jane Doe No. 42 did not respond and never saw Nygard again.
1297. Jane Doe No. 43 is a United States citizen who resides in the United States.
1299. In approximately 2003, Jane Doe No. 43 came to Nygard’s Marina Del Rey
property to sign a contract for a modeling job with the Nygard Companies.
1300. Shortly after signing the contract, Jane Doe No. 43 used the bathroom.
1301. Nygard followed Jane Doe No. 43 into the bathroom and raped her.
1302. Jane Doe No. 43 continued to model for the Nygard Companies because she needed
money.
1303. Nygard attempted to buy Jane Doe No. 43 a vehicle so that she would stay quiet
1304. Defendants also regularly withheld payment from Jane Doe No. 43 as a means to
1305. As part of her modeling for the Nygard Companies, Jane Doe No. 43 frequently
215
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 216 of 270
1306. Nygard attempted to force Jane Doe No. 43 to “recruit” young girls and woman for
1308. Jane Doe No. 44 was part of a child welfare program for indigent youth in
Winnipeg.
1309. Jane Doe No. 44 frequented an area in Winnipeg where there were a lot of indigent
young people.
1310. When Jane Doe No. 44 was approximately fourteen years old, she met Nygard
1311. Nygard promised that he could fly Jane Doe No. 44 to California to attend
1312. Nygard frequently picked Jane Doe No. 44 up and drove her to the Nygard
1313. Nygard asked Jane Doe No. 44 her age and she told him that she was fourteen.
1314. Nygard coerced Jane Doe No. 44 to perform oral sex on him in his car, while parked
1315. Nygard would become very aggressive during Jane Doe No. 44’s sexual encounters
with him.
1316. Nygard would pay Jane Doe No. 44 after each occasion in U.S. currency and would
1317. Nygard would then drop Jane Doe No. 44 off where he picked her up.
1318. Nygard frequently picked Jane Doe No. 44 up for sex over a two-year period.
216
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 217 of 270
1319. Jane Doe No. 45 is a United States citizen that resides in the United States.
1320. In 2009, Jane Doe No. 45 was approached by a woman who claimed to be a talent
agent.
1321. The woman told Jane Doe No. 45 that she could be a model and gave Jane Doe No.
1322. About a week later, the woman called Jane Doe No. 45 and came to her home.
1323. She promised Jane Doe No. 45 that she could be a modeling star.
1324. She told Jane Doe No. 45 that she knew a multi-millionaire, fashion designer that
1325. The woman convinced Jane Doe No. 45 to move-in with her and told her she could
1326. Jane Doe No. 45 did not know that the woman was not actually a talent agent, but
1327. Shortly after moving-in with the woman, the woman began to manipulate and
coerce Jane Doe No. 45 with promises of a modeling career and threats of violence to her and her
family if Jane Doe No. 45 did not do what she told her.
1328. Beginning in around 2010, the woman took Jane Doe No. 45 to several “pamper
parties” to meet Nygard at his Marina Del Rey property, falsely promising that Nygard would
provide Jane Doe No. 45 with a modeling contract for the Nygard Companies.
1329. Nygard paid the woman with funds from the Nygard Companies to engage in
217
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 218 of 270
1330. Jane Doe No. 45 told Nygard that she did not want to have sex with him, but Nygard
1331. Nygard falsely promised Jane Doe No. 45 that he would make her a model. When
Jane Doe No. 45 attempted to resist, Nygard overpowered her and raped her.
1332. The woman continued to sex traffic Jane Doe No. 45 to Nygard on several other
1333. On each occasion, Nygard paid the woman to bring Jane Doe No. 45 to him for
1334. Jane Doe No. 46 is a United States citizen that resides in the United States.
1335. In approximately 2007, Jane Doe No. 46 was working as a runway model.
1336. Jane Doe No. 46 was introduced to Nygard through professional contacts in
Hollywood Hills, California. Jane Doe No. 46 wanted to meet Nygard because she was interested
1337. Nygard offered Jane Doe No. 46 a modeling opportunity in New York City.
1338. Towards the end of 2007, Nygard flew Jane Doe No. 46 and some others to New
1339. Nygard booked Jane Doe No. 46 a room at the W Hotel in New York City through
1340. Nygard is a regular at the W Hotel in New York City and is well known there.
1341. Jane Doe No. 46 was given her own room in a suite.
1342. Jane Doe No. 46 was at the W Hotel for the first day and she he had not yet met
218
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 219 of 270
1343. Jane Doe No. 46 went to sleep in her hotel room at the W Hotel.
1344. Nygard entered Jane Doe No. 46’s hotel room without her permission while she
was sleeping.
1345. Nygard sat on the bed and woke Jane Doe No. 46 up.
1346. He told her she was beautiful and that she should model for the Nygard Companies.
1347. Nygard then requested that Jane Doe No. 46 defecate in his mouth. Jane Doe No.
1348. Nygard became enraged with Jane Doe No. 46’s refusal and began screaming at
her.
1349. Nygard then forced Jane Doe No. 46 to perform oral sex on him and forced oral sex
upon her.
1351. After Nygard orgasmed, he again forced Jane Doe No. 46 to perform oral sex on
1352. Jane Doe No. 47 is a United States citizen who resides in in the United States.
1353. In the late 1980’s or early 1990’s, Jane Doe No. 47 was contacted by a modeling
1354. The modeling agent told her she wanted her to go to the house of the “Calvin Klein
219
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 220 of 270
1355. The modeling agent pitched Jane Doe No. 47 on going to a “pamper party” at
Nygard’s Marina Del Rey property with the understanding that there would be a potential
1356. When Jane Doe No. 47 arrived at Nygard’s Marina Del Rey property, the modeling
1357. Nygard offered to take Jane Doe No. 47 on a tour of the Marina Del Rey property.
1358. When they reached Nygard’s bedroom, Nygard pushed Jane Doe No. 47 on the bed,
1359. After he was done, Nygard told Jane Doe No. 47 that she could take an item from
his “collection.”
1360. Nygard then gave her a VHS video of his “collection” and a photograph of himself.
1361. Jane Doe No. 47 did not tell anyone what happened because she was ashamed and
extremely afraid.
1362. Jane Doe No. 48 is a United States and Canadian citizen who resides in in the
United States.
1363. In 1979, when she was seventeen years old, Jane Doe No. 48 was a college student
1364. Nygard was well-known at the night club scene in Winnipeg and often had his own
1365. After meeting Jane Doe No. 48, Nygard offered to drive her home because she
needed a ride.
220
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 221 of 270
1366. Instead of driving her home as he promised, Nygard took Jane Doe No. 48 to the
1367. The Nygard Companies’ Winnipeg office was equipped with a lofted area that had
1368. Nygard forced Jane Doe No. 48 onto the bed, held her down, and raped her.
1369. After the rape, Nygard drove Jane Doe No. 48 home.
1370. During the car ride, Nygard attempted to negotiate with Jane Doe No. 48 and
1372. In the summer of 1979, Jane Doe No. 49 was fourteen years old and was working
for the Nygard Companies, modeling clothing at the Nygard Companies’ warehouse in Winnipeg,
Canada.
1373. Nygard often took Jane Doe No. 49 to lunch and gave her alcoholic beverages, even
1374. Nygard had Jane Doe No. 49 perform oral sex on him on numerous occasions while
in his car.
1375. On one occasion during the summer of 1979, Nygard got Jane Doe No. 49 drunk at
1376. Nygard digitally penetrated Jane Doe No. 49’s vagina and performed oral sex on
1377. On another occasion during the summer of 1979, an employee of the Nygard
Companies told Jane Doe No. 49 that Nygard wished to see her and brought her to Nygard. When
221
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 222 of 270
she arrived, that same employee stood “lookout” for Nygard while Nygard pinned her against the
wall and attempted to digitally penetrate her vagina. Nygard stopped because the “lookout”
warned Nygard that someone was coming who might see Nygard with Jane Doe No. 49.
1379. In 1998, Jane Doe No. 50 was eighteen years old and was an aspiring model.
1380. Jane Doe No. 50 met Nygard and he asked her to have a business lunch with him
1381. When Nygard arrived, he told Jane Doe No. 50 that he forgot something in his
1384. Nygard forcibly pushed Jane Doe No. 50 onto the bed and began to touch her. He
opened her shirt and bra and began touching her nipples.
1385. Nygard promised Jane Doe No. 50 that if she stayed with him long-term and
traveled with him, she could become a model for the Nygard Companies.
1386. Nygard used his mouth and began sucking Jane Doe No. 50’s nipples.
1387. Nygard propositioned Jane Doe No. 50 to engage in sexual intercourse with him.
1388. Jane Doe No. 50 told Nygard that she was not comfortable because she was
menstruating.
1389. Nygard stated he did not believe her, and without her consent, forced his hand under
her pants and underwear and touched Jane Doe No. 50’s vagina to verify that she was menstruating.
Nygard told her that he did not mind that she was on her period.
222
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 223 of 270
1390. Jane Doe No. 50 told Nygard that she was a virgin and did not want to have sex.
1391. Nygard then went to the door, locked it, and then told Jane Doe No. 50 that he, in
1392. When Jane Doe No. 50 threatened to scream, Nygard replied, “I’m in the
1393. Nygard became angry and threatened Jane Doe No. 50’s safety if she did not have
1394. Jane Doe No. 50 told Nygard that her father would be coming to get her soon.
1395. Nygard reluctantly stated “I have to let you go, you bitch” and Nygard threatened
to ruin Jane Doe No. 50’s modeling career because she had turned him down and escaped.
1397. Jane Doe No. 51 is a United States citizen who resides in the United States.
1398. In 2018, Jane Doe No. 51 began working for the Nygard Companies as an assistant
project manager.
1399. Jane Doe No. 51 was paid by the Nygard Companies via direct deposit, which was
1400. Shortly after starting employment, Nygard attempted to engage in sexual activity
with Jane Doe No. 51 while in Florida. Jane Doe No. 51 told him “no” and he stopped and
apologized.
1401. In September of 2018, Nygard directed Jane Doe No. 51 to travel to New York City
for Fashion Week and offered her a prestigious internship with the Nygard Companies. The
Nygard Companies booked and paid for her flights and accommodations.
223
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 224 of 270
1402. Defendants arranged for Jane Doe No. 51 to stay at Nygard’s penthouse apartment
on the sixth floor of the Nygard Companies’ world headquarters located in Times Square.
1403. When Jane Doe No. 51 arrived, her bags were taken and placed in Nygard’s room
without her knowledge. She was later informed she would be sleeping in Nygard’s room.
1404. On the first night staying at Nygard’s apartment on the sixth floor of the Nygard
Companies’ world headquarters located in Times Square, Nygard demanded sex but Jane Doe No.
51 refused. Nygard then told her that if she was not going to have sex with him, then she would
1405. Having no where else to go, Jane Doe No. 51 slept in Nygard’s room.
1406. The next morning, Nygard forced or coerced Jane Doe No. 51 to perform oral sex
1407. As part of the force and coercion exerted against Jane Doe No. 51 while in New
York, Nygard threw heavy suitcases at Jane Doe No. 51 when she did not do what he wanted
quickly enough.
1408. On another occasion in New York, Nygard struck Jane Doe No. 51, causing her to
1409. Another time, Nygard struck Jane Doe No. 51 in Winnipeg when she did not
1410. Additionally, Nygard forced Jane Doe No. 51 to attend “swingers clubs” with him
1411. While at the “swingers club,” Nygard trafficked Jane Doe No. 51 to another man
224
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 225 of 270
1412. Nygard also required Jane Doe No. 51 to travel with him to locations in California,
Florida, Canada, Alaska, Panama, and the Middle East where Nygard trafficked and/or attempted
1413. While in Canada, Nygard trafficked Jane Doe No. 51 to another man who was a
newly hired employee of the Nygard Companies. Nygard coerced and/or forced Jane Doe No. 51
1414. While in California, Nygard also coerced and/or forced Jane Doe No. 51 to attend
“swingers clubs” in Los Angeles. While at a “swingers club” in Los Angeles, Nygard forcefully
pulled Jane Doe No. 51 by the hair to compel her to have sex with another man.
1415. Additionally, in California, Nygard trafficked Jane Doe No. 51 to another man
1416. While in Florida, Nygard attempted to traffic Jane Doe No. 51 to another man in
1417. While in Panama, Nygard drugged Jane Doe No. 51’s drink, causing her to black
out.
1418. When Jane Doe No. 51 regained alertness, she realized that Nygard, in addition to
1419. Nygard admitted to Jane Doe No. 51 that she had been fighting and kicking at the
men, including Nygard, asking for them to “get off [her]” and “stop.”
1420. On one or more occasions, while in New York, Florida, and/or California, Jane Doe
No. 51 has awoken in the morning to Nygard being on top of her, raping her.
225
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 226 of 270
1421. As an employee of the Nygard Companies, Jane Doe No. 51 had a corporate credit
card, which she was authorized by Nygard to use in a personal capacity, as well as on business
expenses.
1422. Jane Doe No. 52 is a United States citizen who resides in the United States.
1423. In 2019, Jane Doe No. 52 attended several “pamper parties” at Defendants’
1424. At one of the “pamper parties,” Nygard remembered Jane Doe No. 52 and began
1425. Nygard asked Jane Doe No. 52 why she did not attend “pamper parties” more often
and Jane Doe No. 52 responded that she was only able to come if she got a ride. Nygard then
offered Jane Doe No. 52 Uber money and later gave her $500 in cash.
1426. Jane Doe No. 52 remained at the “pamper party” after her friend left to discuss
1427. Nygard offered to show Jane Doe No. 52 a tour of the Marina Del Rey property.
1428. While on the tour, Jane Doe No. 52 went to the bathroom. When she got out of the
1429. Nygard then put pornography on the television. Jane Doe No. 52 felt
1430. Eventually, Nygard began rubbing his penis on Jane Doe No. 52. Jane Doe No. 52
1431. Nygard pushed Jane Doe No. 52 down on the bed, digitally penetrated her anus,
and penetrated her vagina with his penis against her will.
226
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 227 of 270
1432. Afterwards, Jane Doe No. 52 went to the bathroom and Nygard fell asleep.
1433. Jane Doe No. 53 is a United States and Canadian citizen who resides in the United
States.
1434. In approximately 1977, Jane Doe No. 53 was travelling on an airplane flight from
1435. Nygard was a passenger on the same flight and approached Jane Doe No. 53 and
1436. Nygard asked Jane Doe No. 53 for her telephone number and she provided it.
1437. Later, Nygard called Jane Doe No. 53 to ask her to go on a date with him. Jane
Doe agreed.
1438. Nygard first took Jane Doe No. 53 to see the Nygard Companies’ Winnipeg
1439. Nygard then took Jane Doe No. 53 to a restaurant at hotel in Winnipeg.
1440. During dinner, Nygard got Jane Doe No. 53 intoxicated. After dinner he lured Jane
1441. When they arrived at the hotel room, Nygard began making sexual advances.
1442. Jane Doe No. 53 told Nygard that she did not want to have sex, that she was a
1443. Nygard forcibly turned Jane Doe No. 53 over and sodomized her.
1444. After Nygard raped her, Jane Doe No. 53 told Nygard she wanted to leave.
1445. Nygard provided her with money for a taxi and she left.
227
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 228 of 270
1446. Jane Doe No. 54 is a United States citizen who resides in the United States.
1448. In January 2010, when she was eighteen years old, Jane Doe No. 54 met Suelyn
Medeiros (“Medeiros”), one of Nygard’s “girlfriends,” who was also a fairly prominent model at
the time.
1449. Medeiros invited Jane Doe No. 54 to party with her and provided her with alcohol,
even though she knew Jane Doe No. 54 was not 21 years old yet.
1450. After partying all night, Medeiros invited Jane Doe No. 54 to go with her to Nygard
Cay in the Bahamas which was owned by her “friend.” Knowing that Jane Doe No. 54 was a
model, Madeiros lured and enticed Jane Doe No. 54 to travel to the Bahamas by telling Jane Doe
No. 54 that it would be a fun party weekend and that her “friend” owned a fashion company.
1451. Jane Doe No. 54 agreed because she thought that the Nygard Companies would be
1452. Jane Doe No. 54’s flight to the Bahamas was booked through the Nygard
1453. When Jane Doe No. 54, arrived at Nygard Cay she was instructed to check-in at the
1454. The Nygard Companies’ employees registered Jane Doe No. 54 into the ComCor
1456. When Medeiros arrived, she promised Jane Doe No. 54 that she could do anything
228
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 229 of 270
1457. Medeiros offered to take Jane Doe No. 54 to meet her “friend,” Nygard, who was
staying on a yacht anchored off the Cay. Medeiros told Jane Doe No. 54 that she had a room on
the yacht and that is where she and Jane Doe No. 54 would be staying.
1458. Medeiros then took Jane Doe No. 54 to Nygard’s yacht to meet Nygard.
1459. Later, Medeiros intimated to Jane Doe No. 54 that she shouldn’t worry because sex
1460. Jane Doe No. 54 began to panic because she could not leave the property and her
1461. After eluding to the fact that Jane Doe No. 54 would have to have sex with Nygard,
despite her own wishes, Medeiros then told Jane Doe No. 54 that she was leaving early and left
1462. The day after Medeiros left, Jane Doe No. 54 was alone on the beach.
1463. Nygard approached her, grabbed her by the arm, and told her she was going with
1464. Nygard forced Jane Doe No. 54 onto his bed. Jane Doe No. 54 tried to tell him
“no.”
1465. Nygard took her bikini off and forcibly raped Jane Doe No. 54, holding her arms
down.
1466. The next morning, when Jane Doe No. 54 was leaving, Nygard handed her $500 in
U.S. currency.
1467. Employees of the Nygard Companies drove Jane Doe No. 54 to the airport and she
flew home.
229
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 230 of 270
1468. When she got home, Jane Doe No. 54 contacted Medeiros. Medeiros invited Jane
1469. Jane Doe No. 54 agreed because she had friends in Los Angeles. Medeiros told
Jane Doe No. 54 to contact employees of the Nygard Companies to arrange for travel.
1470. Nygard reached out to Jane Doe No. 54 and told Jane Doe No. 54 she had to come
1471. In April 2010, Jane Doe No. 54 traveled to the Bahamas and stayed in the same
1473. After the “pamper party,” in Jane Doe No.54 tried to hide in her room, but Nygard
entered Jane Doe No. 54’s room and made her to come to his room. Nygard raped Jane Doe No.
54 on his bed.
1474. The next day, Nygard gave Jane Doe No. 54 approximately $300 in U.S. currency.
The Nygard Companies arranged and paid for Jane Doe No. 54 to travel to Los Angeles, CA.
1475. Jane Doe No. 55 is a United States citizen who resides in the United States.
1476. In approximately 1980, Jane Doe No. 55 was living on the streets in California.
1478. Nygard picked Jane Doe No. 55 up in a limo and took her to his residence in Playa
1479. Nygard eventually lured and enticed Jane Doe No. 55 to move-in with him by
providing her a place to stay and buying her clothes and other items.
230
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 231 of 270
1480. While Jane Doe No. 55 was staying with Nygard, Nygard knew that she was 14-15
years old and engaged in sexual intercourse with her on numerous occasions.
1481. Nygard also hosted and frequented orgies, during which Nygard forced and/or
1482. Nygard forced and/or coerced Jane Doe No. 55 to have sex with approximately 100
individuals.
1484. In 1980, when she was eighteen years old, Jane Doe No. 56 met Nygard at a night
1485. Jane Doe No. 56 was taken to the Nygard Companies’ building in Winnipeg.
1487. Nygard got on top of Jane Doe No. 56 on a couch and raped her vaginally.
1488. Jane Doe No. 56 resisted and told Nygard to “stop” and to “get off me.”
1489. Afterwards, Jane Doe No. 56 fled and was able to escape.
1490. Jane Doe No. 57 is a United States citizen who resides in the United States.
1491. Jane Doe No. 57 met Nygard in 2007 when she was twenty-two years old and was
working as a model.
1492. In 2009, the Nygard Companies’ corporate travel department arranged and paid for
1493. The Nygard Companies paid for Jane Doe No. 57 to stay in New York City at the
231
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 232 of 270
1494. Nygard enticed Jane Doe No. 57 to have sex with him by paying her with funds
1495. From 2009-2014, Jane Doe No. 57 stayed in New York City with Nygard and others
on numerous occasions.
1496. In approximately 2010 or 2011, Nygard trafficked Jane Doe No. 57 to another man
and coerced her to have sex with him at Nygard’s apartment in New York City.
1497. Nygard also coerced Jane Doe No. 57 to go to “swingers clubs” with him in New
York City.
1498. On numerous occasions, Nygard coerced Jane Doe No. 57 to have sex with other
1499. Jane Doe No. 57 was always paid with U.S. currency from the Nygard Companies
E. The Statute of Limitations Should Be Tolled for All Victims Because Nygard Uses
Threats and Force to Prevent Victims from Pursuing Their Claims and Engaged in a
Continuing Conspiracy and Cover-Up With the Nygard Companies.
the extent applicable, Plaintiffs and the other Class members from bringing their claims, the
applicable statute of limitations is equitably tolled for all Plaintiffs and the other Class members’
claims.
1501. The general rule is that statutes of limitations are subject to equitable tolling. See
United States v. Locke, 471 U.S. 84, 94 n.10 (1985) (”Statutory filing deadlines are generally
subject to the defenses of waiver, estoppel, and equitable tolling.”); Young v. United States, 535
U.S. 43, 49 (2002) (“It is hornbook law that limitations periods are customarily subject to equitable
232
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 233 of 270
tolling unless tolling would be inconsistent with the text of the relevant statute.”) (quotation marks
1502. Plaintiffs, to the extent applicable here, pursued their rights diligently and were
impeded because of a combination of force, threats of force, shame, embarrassment, fear, political
and law enforcement corruption, weak laws that are rarely enforced to protect the victim, and
bribery. As a result, to the extent necessary, all applicable statutes of limitations should be
equitably tolled.
1503. To the extent that Nygard’s victims were unable to pursue their claims, they were
legitimately and justifiably afraid that he would harm and/or retaliate against them if they pursued
1504. As discussed herein, Nygard uses his financial resources, political power, and
influence in the Bahamas and elsewhere, and threats of force to intimidate his victims—including
Jane Does 1-57 and the other Class members—and prevent them from coming forward.
1505. In fact, just recently, Nygard’s attorneys bribed high-level Bahamian police to
determine the identities of victims who were reporting the rapes to officials. There is legitimate
concern that Nygard has attempted or will attempt to do the same in the United States and Canada.
1506. Further, even after his victims leave his control, Nygard often continues to attempt
to contact them, in an intimidating manner, intending to instill fear in his victims and remind them
1507. Due to his power and influence in the Bahamas and worldwide, Nygard’s victims
reasonably believe that he can have them killed if they pursue their claims.
233
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 234 of 270
1508. It is widely believed that Nygard pays thugs and/or the Bahamian police to harass
and threaten his victims by slashing their tires, committing arson, threatening to arrest them, and
1510. Nygard is also believed to have tremendous influence with the Winnipeg police as
1511. Nygard also requires many of his victims and witnesses to his crimes to sign non-
disclosure agreements. Nygard regularly uses Defendants’ wealth to sue and/or threaten to sue his
1512. Nygard threatens to humiliate and/or destroy his victims’ reputations if they come
1513. Nygard threatens to use Defendants’ wealth and influence to destroy his victims’
careers in the modeling industry if they come forward to report his crimes.
1514. Nygard’s illegal conduct also constitutes a recurring pattern and practice of rape,
1515. His rape, sexual assault, and sex trafficking have been occurring continuously,
consistently, and systematically since, at least, 1977 in violation of the TVPRA and various other
1516. Under the continuing violation doctrine, the statute of limitations is tolled for all
victims who have been subjected to his recurring, uniform pattern and practice of sex trafficking,
234
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 235 of 270
1517. Additionally, Plaintiffs’ claims against Nygard and the Nygard Companies are
tolled because Defendants engaged in a continuing conspiracy to commit rape, sexually assault,
1518. Unnamed third-party recruiters and facilitators, and upper-level executives with the
Nygard Companies conspired with Nygard to conceal his crimes for the benefit of all Defendants.
1519. Due to Defendants’ efforts in keeping their conspiracy secret, their conspiracy was
only discovered upon the filing of this class action lawsuit. Therefore, the statute of limitations
for Plaintiffs’ and the other Class members’ conspiracy claims is tolled under the discovery rule.
1520. Plaintiffs Jane Does Nos. 1, 3, 4, 5, 6, 10, 11, 13, 19, 37 44, 48, and 55 bring this
action pursuant to Federal Rule of Civil Procedure 23(b)(3) and 23(c)(4) on behalf of themselves
All women and girls who met with Peter J. Nygard in person while they were under
eighteen years of age: (a) to audition for or to discuss involvement in modeling or
other jobs for any of the Nygard Companies, or (b) in a meeting or event facilitated,
hosted, or underwritten by the Nygard Companies; and with whom Peter J. Nygard
performed a sex act (including, but not limited to: kissing; undressing; touching or
rubbing buttocks, thighs, breasts, or genitalia; penetrating the genitalia, anus, or
mouth; forcing or coercing the individual to penetrate his anus with an object, touch
his genitalia, or urinate or defecate on him; ejaculating on the individual; forcing
the individual to touch another individual in a sexual manner or perform a sex act
on another individual; and/or sedating with drugs or alcohol).
1521. Plaintiffs Jane Does Nos. 7, 8, 9, 12, 14, 15, 16, 17, 18, 20, 21, 22, 23, 24, 25, 26,
27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 38 39, 40, 41, 42, 43, 45, 46, 47, 49, 50, 51, 52, 53, 54, 56,
and 57 bring this action pursuant to Federal Rule of Civil Procedure 23(b)(3) and 23(c)(4) on
behalf of themselves and the following Class (the “Adult Victim Class”):
All women who met with Peter J. Nygard in person while they were eighteen years
of age or over: (a) to audition for or to discuss involvement in modeling or other
jobs for any of the Nygard Companies, or (b) in a meeting or event facilitated,
hosted, or underwritten by the Nygard Companies; and with whom Peter J. Nygard
235
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 236 of 270
performed a sex act (including, but not limited to: kissing; undressing; touching or
rubbing buttocks, thighs, breasts, or genitalia; penetrating the genitalia, anus, or
mouth; forcing or coercing the individual to penetrate his anus with an object, touch
his genitalia, or urinate or defecate on him; ejaculating on the individual; forcing
the individual to touch another individual in a sexual manner or perform a sex act
on another individual; and/or sedating with drugs or alcohol).
1522. Plaintiff Jane Doe No. 2 brings this action pursuant to Federal Rule of Civil
Procedure 23(b)(3) and 23(c)(4) on behalf of herself and the following Subclass (the “Minor
All members of the Minor Victim Class who recruited other women: (a) to audition
for or to discuss involvement in modeling or other jobs for any of the Nygard
Companies; or (b) to attend a meeting or event facilitated, hosted, or underwritten
by the Nygard Companies.
1523. Plaintiffs Jane Does Nos. 8 and 12 bring this action pursuant to Federal Rule of
Civil Procedure 23(b)(3) and 23(c)(4) on behalf of herself and the following Subclass (the “Adult
All members of the Adult Victim Class who recruited other women: (a) to audition
for or to discuss involvement in modeling or other jobs for any of the Nygard
Companies; or (b) to attend a meeting or event facilitated, hosted, or underwritten
by the Nygard Companies.
satisfaction of Fed. R. Civ. P. 23(a)(1). The exact size of the Classes and the identities of the
individual Class members are ascertainable through records maintained by the Defendants,
1525. Plaintiffs’ claims are typical of the claims of the other Class and Subclass members
that they respectively seek to represent. The claims of the Plaintiffs and the other Class members
are based on the same legal theories and arise from the same unlawful pattern and practice of
236
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 237 of 270
1526. There are many questions of law and fact common to the claims of Plaintiffs and
the other Class members, and those questions predominate over any questions that may affect only
individual Class members, within the meaning of Fed. R. Civ. P. 23(a)(2) and (b)(3). Class
treatment of common issues under Fed. R. Civ. P. 23(c)(4) will materially advance the litigation.
1527. Common questions of fact and law affecting Class members include, but are not
a. Whether Nygard engaged in rape, sexual assault, sexual battery, and/or sex
trafficking;
pattern of and propensity for rape, sexual assault, sexual battery, and/or sex
trafficking;
pattern and practice of rape, sexual assault, sexual battery, and/or sex
trafficking;
237
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 238 of 270
h. Whether Defendants violated California Civil Code § 1708.5 and the common
i. Whether the Nygard Companies aided and abetted the violation of California
l. Whether the Nygard Companies aided and abetted the violation of Florida
Canadian law.
o. Whether the Nygard Companies aided and abetted the violation of Canadian
law.
English law.
r. Whether the Nygard Companies aided and abetted the violation of English law.
1528. Absent a class action, most of the Class members would find the cost of litigating
their claims to be cost-prohibitive and will have no effective remedy. The class treatment of
238
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 239 of 270
common questions of law and fact is also superior to multiple individual actions or piecemeal
litigation, in that it conserves the resources of the courts and the litigants and promotes consistency
1529. Plaintiffs will fairly and adequately represent and protect the interests of the other
Class members they respectively seek to represent. Plaintiffs have retained counsel with
substantial experience in prosecuting complex litigation and class actions. Plaintiffs and their
counsel are committed to vigorously prosecuting this action on behalf of the other Class members
and have the financial resources to do so. Neither Plaintiffs nor their counsel have any interests
CLAIMS ALLEGED
COUNT I
1531. Plaintiffs bring this Count individually on behalf of Jane Does Nos. 1, 2, 3, 4, 5, 6,
7, 8, 9, 10, 11, 12, 13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57 and on behalf
1532. Defendants knowingly used the instrumentalities and channels of interstate and
foreign commerce to facilitate violations of 18 U.S.C. § 1591(a)(1), occurring both in and outside
239
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 240 of 270
obtained, advertised, maintained, patronized, or solicited Jane Does Nos. 1, 2, 3, 4, 5, 6, 10, 11,
13, and 19, as well as other members of the Minor Victim Class, for the purpose of causing those
persons to engage in a commercial sex act, and at the time, these individuals were minors under
obtained, advertised, maintained, patronized, or solicited Jane Does Nos. 7, 8, 9, 12, 14, 28, 32,
33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57, as well as other members of the Adult Victim Class,
for the purpose of causing those persons to engage in a commercial sex act, through the use of
1536. Jane Does Nos. 1, 2, 3, 4, 5, 6, 10, 11, 13, and 19, as well as other members of the
Minor Victim Class, did engage in commercial sex acts with Nygard, and, at the time, were under
1537. Jane Does Nos. 7, 8, 9, 12, 14, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57,
as well as other members of the Adult Victim Class, engaged in commercial sex acts with Nygard
or others at Nygard’s direction, due to Nygard’s use of force, fraud and/or coercion.
1538. Defendants provided or promised Jane Does Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12,
13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57, as well as other Class members,
1539. Defendants’ conduct has caused Jane Does Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12,
13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57 and the other Class members
serious and permanent harm, including, without limitation, physical, psychological, financial, and
reputational harm, that is sufficiently serious, under all the surrounding circumstances, to compel
240
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 241 of 270
a reasonable person of the same background and in the same circumstances to perform or to
continue performing commercial sexual activity, in order to avoid incurring that harm.
COUNT II
1541. Plaintiffs bring this Count individually on behalf of Jane Does Nos. 1, 2, 3, 4, 5, 6,
7, 8, 9, 10, 11, 12, 13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57 and on behalf
of other Class and Subclass members they respectively seek to represent against the Nygard
Companies.
1591(a)(2).The Nygard Companies knowingly benefited from, and received value for, their
participation in the venture, in which Nygard, with the Nygard Companies’ knowledge, or in
reckless disregard of the fact, that Nygard would defraud, force, and/or coerce Jane Does Nos. 1,
2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46 51, 52, 54, and 57, as
well as other members of the Classes, some of whom were under the age of eighteen, to engage in
1543. The Nygard Companies knew, or were in reckless disregard of the fact, that it was
Nygard’s pattern and practice to use the channels and instrumentalities of interstate and foreign
commerce, as well as the Nygard Companies’ resources to entice or recruit young and underage
aspiring female models into commercial sex acts, based upon the promise of lucrative modeling
241
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 242 of 270
1544. Nygard and other Nygard Companies’ employees had actual knowledge that they
were facilitating and participating in Nygard’s use of company resources to recruit, entice, coerce,
and/or solicit Jane Does Nos. 1, 2, 3, 4, 5, 6, 10, 11, 13, and 19, as well as other members of the
Minor Victim Class, into commercial sex acts, who, at the time, were under the age of eighteen
years old.
1545. Nygard and other Nygard Companies’ employees had actual knowledge that they
were facilitating Nygard’s use of company resources to recruit, entice, coerce, and/or solicit Jane
Does Nos. 7, 8, 9, 12, 14, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57, as well as other
members of the Adult Victim Class, into commercial sex acts, through the use of force, fraud,
and/or coercion.
1546. Despite such knowledge, the Nygard Companies paid for, facilitated, and
participated in Nygard’s violations of 18 U.S.C. § 1591, where the Nygard Companies knew, or
were in reckless disregard of the facts that, Nygard would encounter aspiring models seeking to
do business with the Nygard Companies, who were either under the age of eighteen, or coerced,
1547. The Nygard Companies’ employees and/or agents actively participated in the
scheme that led Jane Does Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 19, 28, 32, 33, 34, 39,
41, 43, 45, 46, 51, 52, 54, and 57, as well as other members of the Classes, to believe that they
1548. This affirmative conduct of the Nygard Companies was committed knowing, or in
reckless disregard of the facts that, Nygard would use Nygard Companies’ money, the promise of
a modeling career, and his influence in the fashion industry, which were things of value, as a means
242
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 243 of 270
of defrauding, forcing, and/or coercing sex acts from Jane Does Nos. 7, 8, 9, 12, 14, 28, 32, 33,
34, 39, 41, 43, 45, 46, 51, 52, 54, and 57, as well as other members of the Adult Victim Class.
1549. Upon information and belief, in exchange for facilitating and covering up Nygard’s
commercial sex acts, the Nygard Companies’ employees, progressed in their careers at the Nygard
1551. The Nygard Companies knowingly benefited financially from Nygard’s sex-
trafficking venture.
1552. By facilitating Nygard’s commercial sex acts in foreign commerce, the Nygard
Companies enjoyed the promotion and promulgation of the Nygard Companies’ projects
internationally.
1553. Nygard is the face of the Nygard Companies, and his presence and promotion in
1554. The Nygard Companies facilitated Nygard’s commercial sex acts in foreign
commerce to obtain the enormous publicity that Nygard garnered by promoting the Nygard
1555. The Nygard Companies also benefited from the services that Nygard’s sex workers
were forced to provide to the Companies including, without limitation, modeling company
clothing for company executives, preparing Nygard for his business meetings, attending business
meetings, developing clothing design ideas, and perpetuating Nygard’s playboy image, which is a
243
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 244 of 270
1556. The Nygard Companies’ brand also benefited financially from the promotion and
advertisement of “pamper parties,” Nygard Cay, and Peter Nygard’s playboy persona by
1557. The Nygard Companies also used “pamper parties” at the Nygard Cay, Bahamas
and the Marina Del Ray, California locations to promote their products and brands.
1558. The Nygard Companies also used the World Headquarters and New York
apartment above the World Headquarters for “sex parties” to promote their products and brands.
1559. The Nygard Companies’ conduct has caused Jane Does Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9,
10, 11, 12, 13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57 and the other members
of the Classes serious harm including, without limitation, physical, psychological, financial, and
reputational harm, that is sufficiently serious, under all the surrounding circumstances, to compel
a reasonable person of the same background and in the same circumstances to perform or to
continue performing commercial sexual activity, in order to avoid incurring that harm.
COUNT III
1561. Plaintiffs bring this Count individually on behalf of Jane Does Nos. 1, 2, 3, 4, 5, 6,
7, 8, 9, 10, 11, 12, 13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57 and on behalf
Nygard’s unlawful plan and/or purpose to commit illegal commercial sex acts with Jane Does Nos.
244
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 245 of 270
1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57
1563. The Nygard Companies committed overt acts in furtherance of the agreement or
understanding by playing an active role in recruiting, enticing, coercing, and inducing Jane Does
Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54,
and 57 and other members of the Classes, through promises of lucrative modeling opportunities
and connections and influence that would substantially advance their careers.
1564. The Nygard Companies’, participation in the furtherance of Nygard’s illegal sex
trafficking plan and/or purpose was intentional and/or willful and, therefore, the Nygard
Companies intentionally and/or willfully caused Nygard’s commission of the sex acts with Jane
Does Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52,
54, and 57 and other Class members in its affirmative acts supporting Nygard.
1565. The Nygard Companies knew that their acts and conduct supporting and facilitating
Nygard would lead to unlawful commercial sex acts by Nygard with young women and children,
who were aspiring models, including Jane Does Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 19,
28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57 and other members of the Classes.
1566. The Nygard Companies’ conspired with Nygard through their affirmative acts and
provided substantial support to Nygard committing commercial sex acts upon Jane Does Nos. 1,
2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57 and
1567. The Nygard Companies’ conduct has caused Jane Does Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9,
10, 11, 12, 13, 14, 19, 28, 32, 33, 34, 39, 41, 43, 45, 46, 51, 52, 54, and 57 and other members of
the Classes serious harm, including, without limitation, physical, psychological, financial, and
245
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 246 of 270
reputational harm, that is sufficiently serious, under all the surrounding circumstances, to compel
a reasonable person of the same background and in the same circumstances to perform or to
continue performing commercial sexual activity in order to avoid incurring that harm.
COUNT IV
1569. Plaintiffs bring this Count individually on behalf of Jane Does Nos. 9, 17, 21, 24,
25, 29, 30, 38, 43, 45, 47, 52, and 55 and on behalf of other Class and Subclass members they
1570. Nygard intentionally committed sexual battery and/or intentionally caused other
individuals to commit sexual battery on Jane Doe Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52,
and 55 and other members of the Classes in the State of California in violation of California law.
1571. Nygard acted with the intent to cause a harmful and offensive contact with an
intimate part of Plaintiffs Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55, as
well as other members of the Classes, and a sexually offensive contact directly or indirectly
resulted.
1572. Nygard acted with the intent to cause a harmful and offensive contact with Jane
Plaintiffs Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55, as well as other members
of the Classes, by use of his intimate part and a sexually offensive contact directly or indirectly
resulted.
246
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 247 of 270
1573. Nygard also acted to cause an imminent apprehension or fear of a harmful and
offensive contact with Plaintiffs Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and
1574. Plaintiffs Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and
other members of the Classes did not consent to Nygard’s harmful and offensive contact and/or
1575. Plaintiffs Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and
other members of the Classes were harmed and/or offended by Nygard’s conduct. Nygard’s
conduct has caused Plaintiffs Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55
and other members of the Classes serious and permanent harm and/or damages, including, without
COUNT V
1577. Plaintiffs bring this Count individually on behalf of Jane Does Nos. 9, 17, 21, 24,
25, 29, 30, 38, 43, 45, 47, 52, and 55 and on behalf of other Class and Subclass members they
1578. The Nygard Companies knowingly aided and abetted, facilitated, and enabled
Nygard’s sexual battery of Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and
other members of the Classes, occurring in the State of California in violation of California law.
1579. The Nygard Companies knew, or should have known, that Nygard’s conduct
247
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 248 of 270
accomplishing his breach of duty and/or tortious conduct and the Nygard Companies’ conduct,
separately considered, constitutes a breach of duty to Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38,
43, 45, 47, 52, and 55 and other members of the Classes.
1582. The Nygard Companies, through Nygard and other Nygard Companies’ employees,
had actual knowledge that they were providing substantial assistance by facilitating, aiding and
abetting, and participating in Nygard’s use of company resources to commit sexual battery against
Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and other members of the
Classes.
1583. Despite such knowledge, the Nygard Companies paid for, facilitated, and aided and
abetted Nygard’s sexual battery of Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, and 45 and
1584. The Nygard Companies’ employees knowingly facilitated and aided and abetted
Nygard’s sexual battery of Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and
other members of the Classes because they believed that they would be rewarded with substantial
1585. This affirmative conduct of the Nygard Companies was committed knowing, or in
reckless disregard of the facts that, Nygard would use the Nygard Companies’ money and brand,
the promise of a modeling career, and his influence in the fashion industry to commit sexual battery
against Jane Doe Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and other members of
the Classes.
248
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 249 of 270
1586. In exchange for facilitating, aiding and abetting, and covering up Nygard’s sexual
battery of Jane Doe Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and other members of
the Classes, the Nygard Companies’ employees progressed in their careers at the Nygard
1587. Participating in, aiding and abetting, and covering up Nygard’s sexual misconduct
was a means of obtaining success and growth within the Nygard Companies’ hierarchy.
1588. Plaintiffs Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and
other members of the Classes have been damaged as a direct result of the Nygard Companies’
conduct.
1589. The Nygard Companies’ conduct has caused Jane Does Nos. 9, 17, 21, 24, 25, 29,
30, 38, 43, 45, 47, 52, and 55 and other members of the Classes serious and permanent harm and/or
reputational harm.
COUNT VI
1591. Plaintiffs bring this Count individually on behalf of Jane Does Nos. 9, 17, 21, 24,
25, 29, 30, 38, 43, 45, 47, 52, and 55, and on behalf of other Class and Subclass members they
sexual battery and to cover-up their conspiracy for over four decades.
249
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 250 of 270
1593. Defendants formed a group of two or more persons and agreed to a common plan
or design to commit tortious acts, including sexual assault and/or sexual battery.
1594. All Defendants had actual knowledge that sexual assault and/or sexual battery was
planned and concurred in the tortious scheme with knowledge of its unlawful purpose.
1595. Defendants intended to aid in the commission of the planned tort, including sexual
1596. Defendants committed numerous wrongful acts, including sexual assault and/or
sexual battery, against Plaintiffs Jane Does Nos. 9, 17, 21, 24, 25, 30, 38, 43, 45, 47, 52, and 55
and other members of the Classes occurring in the State of California pursuant to their agreement.
1597. The Nygard Companies also committed wrongful acts by knowingly luring and
enticing Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and other members of
the Classes to locations where Defendants knew Nygard would sexually assault and/or sexually
batter them.
1598. The Nygard Companies also committed wrongful and/or overt acts by knowingly
providing Nygard with the resources to sexually assault and/or sexually batter Jane Does Nos. 9,
17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and other members of the Classes.
1599. The Nygard Companies’ employees carried out the acts and omissions constituting
the alleged conspiracy within their actual or ostensible authority with the Nygard Companies.
1600. The acts and omissions of the Nygard Companies’ employees were carried out in
and during the course of their employment with the Nygard Companies.
1601. The Nygard Companies’ employees conspired with Nygard because they believed
that they would be rewarded with substantial career-advancing opportunities if they cooperated
250
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 251 of 270
1602. This affirmative conduct of the Nygard Companies was committed by express
and/or implied agreement that Nygard would use the Nygard Companies’ money and brand, the
promise of a modeling career, and his influence in the fashion industry to commit sexual assault
and/or sexual battery against Plaintiffs Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52,
1603. In exchange for conspiring to facilitate and cover-up Nygard’s sexual assault and/or
sexual battery of Plaintiffs Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and
other members of the Classes, the Nygard Companies’ employees progressed in their careers at
1604. Conspiring with Nygard and covering up his sexual misconduct was a means of
1605. Plaintiffs Jane Does Nos. 9, 17, 21, 24, 25, 29, 30, 38, 43, 45, 47, 52, and 55 and
other members of the Classes were damaged as a direct result of Defendants’ agreement.
1606. Defendants’ conduct has caused Plaintiffs Jane Does Nos. 9, 17, 21, 24, 25, 29, 30,
38, 43, 45, 47, 52, and 55 and other members of the Classes serious and permanent harm and/or
reputational harm.
COUNT VII
1608. Plaintiffs bring this Count individually on behalf of Jane Does Nos. 31, 41, and 54
and on behalf of other Class and Subclass members they respectively seek to represent.
251
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 252 of 270
1609. Nygard intentionally committed sexual battery and/or intentionally caused other
individuals to commit sexual battery on Jane Does Nos. 31, 41, and 54 and other members of the
Classes in the State of Florida and/or committed acts in the State of Florida that led to their sexual
1610. Nygard intentionally caused oral, anal, and/or vaginal penetration by, or union with,
the sexual organ of himself or another or the anal or vaginal penetration of Jane Does Nos. 31, 41,
1611. Plaintiffs Jane Does Nos. 31, 41, and 54 and other members of the Classes did not
consent to such harmful and offensive contact and/or were coerced into such harmful and offensive
contact.
1612. Plaintiffs Jane Does Nos. 31, 41, and 54 and other members of the Classes were
1613. Defendants’ conduct has caused Plaintiffs Jane Does Nos. 31, 41, and 54 and other
members of the Classes serious and permanent harm and/or damage, including, without limitation,
COUNT VIII
1615. Plaintiffs bring this Count individually on behalf of Jane Does Nos. 31, 41, and 54
and on behalf of other Class and Subclass members they respectively seek to represent.
1616. Nygard, the primary wrongdoer, committed numerous underlying violations of law
252
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 253 of 270
1617. The Nygard Companies, through Nygard and their upper-level employees, had
actual knowledge of Nygard’s violations of law and/or wrongful acts, including sexual assault
1618. Despite this knowledge, the Nygard Companies aided and abetted, facilitated, and
enabled Nygard’s sexual battery of Jane Does Nos. 31, 41, and 54 and other members of the
Classes occurring in the State of Florida and/or committed acts in the State of Florida that led to
committing the wrongdoing and the Nygard Companies’ conduct, separately considered,
constitutes a breach of duty to Jane Does Nos. 31, 41, and 54 and other members of the Classes.
1621. The Nygard Companies, through Nygard and other Nygard Companies’ employees,
had actual knowledge that they were facilitating, aiding and abetting, and participating in Nygard’s
use of company resources and brand to commit sexual battery against Jane Does Nos. 31, 41, and
1622. Despite such knowledge, the Nygard Companies paid for, facilitated, and aided and
abetted Nygard’s sexual battery of Jane Does Nos. 31, 41, and 54 and other members of the
Classes.
1623. The Nygard Companies’ employees facilitated and aided and abetted Nygard’s
sexual battery of Jane Does Nos. 31, 41, and 54 and other members of the Classes because they
believed that they would be rewarded with substantial career-advancing opportunities if they
253
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 254 of 270
1624. This affirmative conduct of the Nygard Companies was committed knowing, or in
reckless disregard of the facts, that Nygard would use the Nygard Companies’ money and brand,
the promise of a modeling career, and his influence in the fashion industry to commit sexual battery
against Jane Does Nos. 31, 41,and 54 and other members of the Classes.
1625. In exchange for facilitating, aiding and abetting, and covering up Nygard’s sexual
battery of Jane Does Nos. 31, 41, and 54 and other members of the Classes, the Nygard Companies’
employees progressed in their careers at the Nygard Companies and received financial benefits
therefor.
1626. Participating in, aiding and abetting and covering up Nygard’s sexual misconduct
was a means of obtaining success and growth within the Nygard Companies’ hierarchy.
1627. Plaintiffs Jane Does Nos. 31, 41, and 54 and other members of the Classes have
1628. The Nygard Companies’ conduct has caused Jane Does Nos. 31, 41, and 54 and
other members of the Classes serious and permanent harm and/or damages, including, without
COUNT IX
1630. Plaintiffs bring this Count individually on behalf of Jane Does Nos. 31, 41, and 54
and on behalf of other Class and Subclass members they respectively seek to represent.
sexual battery and to cover-up their conspiracy for over four decades.
254
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 255 of 270
1632. Defendants formed a group of two or more parties and agreed to a common plan or
design to commit unlawful acts and/or to do lawful acts by unlawful means, including sexual
1634. All Defendants had actual knowledge that sexual assault and/or sexual battery was
planned and concurred in the tortious scheme with knowledge of its unlawful purpose.
1635. Defendants intended to aid in the commission of the planned tort, including sexual
1636. Defendants committed numerous wrongful and/or overt acts, including sexual
assault and/or sexual battery, against Jane Does Nos. 31, 41, and 54 and other members of the
1637. The Nygard Companies also committed wrongful and/or overt acts by knowingly
luring and enticing Jane Does Nos. 31, 41, and 54 and other members of the Classes from the State
of Florida to locations where Defendants knew Nygard would sexually assault and/or sexually
batter them.
1638. The Nygard Companies also committed wrongful and/or overt acts by knowingly
providing Nygard with the resources to sexually assault and/or sexually batter Jane Does Nos. 31,
1639. The Nygard Companies’ employees carried out the acts and omissions constituting
the alleged conspiracy within their actual or ostensible authority with the Nygard Companies.
1640. The acts and omissions of the Nygard Companies’ employees were carried out in
and during the course of their employment with the Nygard Companies.
255
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 256 of 270
1641. The Nygard Companies’ employees conspired with Nygard because they believed
that they would be rewarded with substantial career-advancing opportunities if they cooperated
1642. This affirmative conduct of the Nygard Companies was committed by express
and/or implied agreement that Nygard would use the Nygard Companies’ money and brand, the
promise of a modeling career, and his influence in the fashion industry to commit sexual battery
against Plaintiffs Jane Does Nos. 31, 41, and 54 and other members of the Classes.
1643. In exchange for conspiring to facilitate and cover-up Nygard’s rape and/or sexual
battery of Plaintiffs Jane Does Nos. 31, 41, and 54 and other members of the Classes, the Nygard
Companies’ employees progressed in their careers at the Nygard Companies and received financial
benefits therefor.
1644. Conspiring with Nygard and covering up his sexual misconduct was a means of
1645. Plaintiffs Jane Does Nos. 31, 41, and 54 and other members of the Classes were
1646. Defendants’ conduct has caused Plaintiffs Jane Does Nos. 31, 41, and 54 and other
members of the Classes serious and permanent harm and/or damages, including, without
COUNT X
256
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 257 of 270
1648. Plaintiffs bring this Count individually on behalf of Jane Does Nos. 14, 15, 16, 18,
19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and on behalf of other
1649. Nygard intentionally committed sexual assault and sexual battery and/or
intentionally caused other individuals to commit sexual assault and sexual battery on Jane Does
Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and
1650. Nygard’s sexual assault and sexual battery of Jane Does Nos. 14, 15, 16, 18, 19,
20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and other members of the
Classes occurred in Canada and/or against Canadian citizens via conduct that largely occurred in
Canada.
1651. Nygard intentionally put Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28,
32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and other members of the Classes in fear of harm
1652. Nygard also utilized the intentional application of force against Jane Does Nos. 14,
15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56, and other
members of the Classes and violated their sexual integrity without their consent.
1653. Nygard acted with the intent to cause a harmful and offensive contact with an
intimate part of Plaintiffs Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37,
40, 42, 44, 48, 49, 50, 53, and 56 , as well as other members of the Classes, and a sexually offensive
1654. Nygard acted with the intent to cause a harmful and offensive contact with Jane
Plaintiffs Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49,
257
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 258 of 270
50, 53, and 56, as well as other members of the Classes, by use of his intimate part and a sexually
1655. Nygard also acted to cause an imminent apprehension or fear of a harmful and
offensive contact with Plaintiffs Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35,
36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 ’s, as well as other members of the Classes’, intimate
parts.
1656. Plaintiff Jane Doe Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40,
42, 44, 48, 49, 50, 53, and 56 and other members of the Classes did not consent to such harmful
and offensive contact and/or were coerced in to such harmful and offensive contact.
1657. Plaintiff Jane Doe Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40,
42, 44, 48, 49, 50, 53, and 56 and other members of the Classes were harmed and/or damaged by
1658. Defendants’ conduct has caused Plaintiff Jane Does Nos. 14, 15, 16, 18, 19, 20, 21,
23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56and other members of the Classes
serious and permanent harm and/or damages, including, without limitation, physical,
COUNT XI
1660. Plaintiffs bring this Count individually on behalf of Jane Doe Nos. 14, 15, 16, 18,
19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 , and on behalf of other
258
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 259 of 270
1661. The Nygard Companies aided and abetted, facilitated, and enabled Nygard’s sexual
battery of Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48,
49, 50, 53, and 56 and other members of the Classes in violation of Canadian law.
1662. The Nygard Companies aided and abetted, facilitated, and enabled Nygard’s sexual
assault and/or sexual battery of Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35,
36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 , in large part, from conduct occurring in and/or originating
from Canada.
1663. The Nygard Companies knew, or should have known, that Nygard’s conduct
accomplishing his breach of duty and/or tortious conduct and the Nygard Companies’ conduct,
separately considered, constitutes a breach of duty to Jane Does Nos. 14, 15, 16, 18, 19, 20, 21,
23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and other members of the Classes.
1666. The Nygard Companies, through Nygard and other Nygard Companies’ employees,
had actual knowledge that they were facilitating, aiding and abetting, and enabling Nygard’s use
of the Nygard Companies’ resources and brand to commit sexual battery against Jane Doe Nos.
14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and
1667. Despite such knowledge, the Nygard Companies paid for, facilitated, and aided and
abetted Nygard’s sexual battery of Jane Doe Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35,
36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and other members of the Classes.
259
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 260 of 270
1668. The Nygard Companies’ employees facilitated and aided and abetted Nygard’s
sexual battery of Jane Doe Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42,
44, 48, 49, 50, 53, and 56 and other members of the Classes because they believed that they would
Nygard’s demands.
1669. This affirmative conduct of the Nygard Companies was committed knowing, or in
reckless disregard of the facts that, Nygard would use the Nygard Companies’ money and brand,
the promise of a modeling career, and his influence in the fashion industry to commit sexual battery
against Jane Doe Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49,
1670. In exchange for facilitating, aiding and abetting, and covering up Nygard’s sexual
battery of Jane Doe Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48,
49, 50, 53, and 56 and other members of the Classes, the Nygard Companies’ employees
progressed in their careers at the Nygard Companies and received financial benefits therefor.
1671. Participating in, aiding and abetting, and covering up Nygard’s sexual misconduct
was a means of obtaining success and growth within the Nygard Companies’ hierarchy.
1672. Plaintiffs Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37,
40, 42, 44, 48, 49, 50, 53, and 56 and other members of the Classes have been damaged as a direct
1673. The Nygard Companies’ conduct has caused Jane Does Nos. 14, 15, 16, 18, 19, 20,
21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and other members of the
Classes serious and permanent harm and/or damages, including, without limitation, physical,
260
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 261 of 270
COUNT XII
1675. Plaintiffs bring this Count individually on behalf of Jane Doe Nos. 14, 15, 16, 18,
19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 , and on behalf of other
sexual battery and to cover-up their conspiracy for over four decades.
1677. Defendants formed a group of two or more persons and acted in concert, by
agreement, with a common design and intention to commit unlawful, acts including sexual assault
1678. Defendants were aware of the relevant facts and intended to participate in the
conspiracy.
1679. Defendants engaged in conduct that was unlawful by carrying out an underlying
causing injury to Plaintiffs Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36,
37, 40, 42, 44, 48, 49, 50, 53, and 56 and other members of the Classes, notwithstanding that the
1681. Defendants committed numerous wrongful acts, including sexual assault and/or
sexual battery, against Plaintiffs Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35,
36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and other members of the Classes.
261
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 262 of 270
1682. The Nygard Companies also committed wrongful and/or overt acts by knowingly
luring and enticing Jane Does Nos. 14, 15, 16, 18, 19, 20, 23, 26, 27, 28, 35, 36, 37, 40, 42, 44, 48,
49, 50, 53, and 56 and other members of the Classes to locations where Defendants knew Nygard
1683. The Nygard Companies also committed wrongful and/or overt acts by knowingly
providing Nygard with the resources to sexually assault and/or sexually batter Jane Does Nos. 14,
15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and other
1684. The Nygard Companies’ employees carried out the acts and omissions constituting
the alleged conspiracy within their actual or ostensible authority with the Nygard Companies.
1685. The acts and omissions of the Nygard Companies’ employees were carried out in
and during the course of their employment with the Nygard Companies.
1686. Defendants’ conduct was directed towards Plaintiffs Jane Does Nos. 14, 15, 16, 18,
19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and other members of
the Classes.
1687. Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44,
48, 49, 50, 53, and 56 and other members of the Classes are Canadian citizens that were sexually
assaulted and/or battered by Nygard in Canada and/or the Bahamas due to substantial conduct of
1688. The Nygard Companies’ conspiracy with Nygard to sexually assault and/or
sexually batter Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44,
48, 49, 50, 53, and 56 arose and/or formed, in large part, in Canada.
262
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 263 of 270
1690. The Nygard Companies’ employees conspired with Nygard because they believed
that they would be rewarded with substantial career-advancing opportunities if they cooperated
1691. This affirmative conduct of the Nygard Companies was committed knowing, or in
reckless disregard of the facts that, Nygard would use the Nygard Companies’ money and brand,
the promise of a modeling career, and his influence in the fashion industry to commit sexual battery
against Plaintiffs Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42,
44, 48, 49, 50, 53, and 56 and other members of the Classes.
1692. In exchange for facilitating and covering up Nygard’s sexual battery of Plaintiffs
Jane Does Nos. 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and
56 and other members of the Classes, the Nygard Companies’ employees progressed in their
1694. Given the circumstances, Defendants should have known that injury was likely to
result.
1695. Plaintiffs Jane Does Nos. 14, 15, 16, 18, 19, 20, 21, 23, 26, 27, 28, 32, 35, 36, 37,
40, 42, 44, 48, 49, 50, 53, and 56 and other members of the Classes were damaged as a direct result
of Defendants’ agreement.
1696. Defendants’ conduct has caused Plaintiffs Jane Does Nos. 14, 15, 16, 18, 19, 20,
21, 23, 26, 27, 28, 32, 35, 36, 37, 40, 42, 44, 48, 49, 50, 53, and 56 and other members of the
263
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 264 of 270
Classes serious and permanent harm, including, without limitation, physical, psychological,
COUNT XIII
1698. Plaintiffs bring this Count individually on behalf of Jane Doe Nos. 22 and 37, and
on behalf of other Class and Subclass members they respectively seek to represent.
1699. Nygard intentionally committed rape, sexual assault, and/or sexual battery and/or
intentionally caused other individuals to commit rape, sexual assault, and/or sexual battery on Jane
Doe Nos. 22 and 37 and other members of the Classes in the United Kingdom in violation of
English law.
1700. Nygard acted with the intent to cause a harmful and offensive contact that was
sexual in nature against Plaintiffs Jane Does Nos. 22 and 37, as well as other members of the
1701. Nygard also acted to cause an imminent apprehension or fear of a harmful and
offensive contact that was sexual in nature with Plaintiffs Jane Does Nos. 22 and 37’s, as well as
1702. Plaintiff Jane Doe Nos. 22 and 37 and other members of the Classes did not consent
to such harmful and offensive sexual contact and/or were coerced in to such harmful and offensive
sexual contact.
1703. Nygard did not reasonably believe that Jane Doe Nos. 22 and 37 and other members
264
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 265 of 270
1704. Plaintiff Jane Doe Nos. 22 and 37 and other members of the Classes were harmed
1705. Defendants’ conduct has caused Plaintiff Jane Does Nos. 22 and 37 and other
members of the Classes serious and permanent harm, including, without limitation, physical,
COUNT XIV
1707. Plaintiffs bring this Count individually on behalf of Jane Doe Nos. 22 and 37 and
on behalf of other Class and Subclass members they respectively seek to represent.
1708. The Nygard Companies aided and abetted Nygard’s sexual battery of Jane Does
Nos. 22 and 37 and other members of the Classes in violation of English law.
1709. The Nygard Companies knew, or should have known, that Nygard’s conduct
1710. The Nygard Companies knowingly gave substantial assistance, solicited, and/or
duty and/or tortious conduct against Jane Does Nos. 22 and 37 and other members of the Classes.
1712. The Nygard Companies, through Nygard and other Nygard Companies’ agents
and/or employees, had actual knowledge that they were participating in Nygard’s use of the
Nygard Companies’ resources and brand to commit rape, sexual battery, and/or sexual assault
against Jane Doe Nos. 22 and 37 and other members of the Classes.
265
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 266 of 270
1713. Despite such knowledge, the Nygard Companies paid for, solicited, incited, and
aided and abetted Nygard’s sexual battery of Jane Doe Nos. 22 and 37 and other members of the
Classes.
1714. The Nygard Companies’ employees and/or agents aided and abetted Nygard’s
sexual battery of Jane Doe Nos. 22 and 37 and other members of the Classes because they believed
that they would be rewarded with substantial career-advancing opportunities if they cooperated
1715. This affirmative conduct of the Nygard Companies was committed knowing, or in
reckless disregard of the facts that, Nygard would use the Nygard Companies’ money and brand,
the promise of a modeling career, and his influence in the fashion industry to commit rape, sexual
battery, and/or sexual assault against Jane Doe Nos. 22 and 37 and other members of the Classes.
1716. In exchange for aiding and abetting and covering up Nygard’s rape, sexual battery,
and/or sexual assault of Jane Doe Nos. 22 and 37 and other members of the Classes, the Nygard
Companies’ employees and/or agents progressed in their careers at the Nygard Companies and
1718. Plaintiffs Jane Does Nos. 22 and 37 and other members of the Classes have been
1719. The Nygard Companies’ conduct has caused Jane Does Nos. 22 and 37 and other
members of the Classes serious and permanent harm, including, without limitation, physical,
266
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 267 of 270
COUNT XV
1721. Plaintiffs bring this Count individually on behalf of Jane Doe Nos. 22 and 27 and
on behalf of other Class and Subclass members they respectively seek to represent.
sexual battery and to cover-up their conspiracy for over four decades.
1723. Defendants formed a group of two or more persons and agreed to a common plan
1724. Defendants took concerted action and/or committed numerous wrongful and/or
overt acts against Plaintiffs Jane Does Nos. 22 and 37 and other members of the Classes in the
1725. The Nygard Companies also committed wrongful and/or overt acts by knowingly
luring and enticing Jane Does Nos. 22, and 37 and other members of the Classes to locations where
Defendants knew Nygard would sexually assault and/or sexually batter them.
1726. The Nygard Companies also committed wrongful and/or overt acts by knowingly
providing Nygard with the resources to sexually assault and/or sexually batter Jane Does Nos. 22,
1727. The Nygard Companies’ employees carried out the acts and omissions constituting
the alleged conspiracy within their actual or ostensible authority with the Nygard Companies.
1728. The acts and omissions of the Nygard Companies’ employees were carried out in
and during the course of their employment with the Nygard Companies.
267
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 268 of 270
1729. The dominant purpose of Defendants’ conspiracy was to damage Jane Does Nos.
22 and 37 and other members of the Classes and Defendants did actually damage Jane Does Nos.
1730. Defendants intended to damage Jane Does Nos. 22 and 37 and other members of
the Classes.
1731. The Nygard Companies’ employees conspired with Nygard because they believed
that they would be rewarded with substantial career-advancing opportunities if they cooperated
1732. This affirmative conduct of the Nygard Companies was committed knowing, or in
reckless disregard of the facts that, Nygard would use the Nygard Companies’ money and brand,
the promise of a modeling career, and his influence in the fashion industry to commit sexual battery
against Plaintiffs Jane Does Nos. 22 and 37 and other members of the Classes.
1733. Upon information and belief, in exchange for facilitating and covering up Nygard’s
sexual battery of Plaintiffs Jane Does Nos. 22 and 37 and other members of the Classes, the Nygard
Companies’ employees progressed in their careers at the Nygard Companies and received financial
benefits therefor.
1735. Plaintiffs Jane Does Nos. 22 and 37 and other members of the Classes were
1736. Defendants’ conduct has caused Plaintiffs Jane Does Nos. 22 and 37 and other
members of the Classes serious and permanent harm, including, without limitation, physical,
268
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 269 of 270
Plaintiffs respectfully request that the Court enter judgment in their favor, and against
Defendants, as follows:
a. That the Court certify the Classes, name Plaintiffs as Class Representatives, and
b. That the Court grant permanent injunctive relief to prohibit Defendants from
c. That the Court award Plaintiffs and the other members of the Classes compensatory,
at trial;
e. That the Court award to Plaintiffs the costs and disbursements of the action, along
f. That the Court award pre- and post-judgment interest at the maximum legal rate;
and
g. That the Court grant all such other relief as it deems just and proper.
JURY DEMAND
269
Case 1:20-cv-01288-ER Document 48 Filed 06/11/20 Page 270 of 270
Adam J. Levitt
Amy E. Keller (pro hac vice)
DICELLO LEVITT GUTZLER LLC
Ten North Dearborn Street, SixthFloor
Chicago, Illinois 60602
Tel.: 312-214-7900
[email protected]
[email protected]
Mark A. DiCello
Robert F. DiCello (pro hac vice)
Justin J. Hawal (pro hac vice)
DICELLO LEVITT GUTZLER LLC
7556 Mentor Avenue
Mentor, Ohio 44060
Tel.: 440-953-8888
[email protected]
[email protected]
[email protected]
270