Electronically Filed

11/15/2021 5:00 PM
Steven D. Grierson
CLERK OF THE COURT

1 JENNY L. FOLEY, Ph.D., ESQ.

Nevada Bar No. 9017
2 E-mail: jfoley@hkm.com
3 HKM EMPLOYMENT ATTORNEYS LLP
1785 East Sahara, Suite 300 CASE NO: A-21-844132-C
4 Las Vegas, Nevada 89104 Department 15
Tel: (702) 805-8340
5 Fax: (702) 805-8340
Attorneys for Plaintiff
6
7
EIGHTH JUDICIAL DISTRICT COURT
8 CLARK COUNTY, NEVADA

9 GAHYNE DOAHE, an Individual,

CASE NO.:
10
Plaintiff,
11
vs. COMPLAINT AND JURY DEMAND
12
DAVID MARLON, an Individual, JOHN
13
SEELAND, an Individual, CROSSROADS
14 OF SOUTHERN NEVADA, A Nevada
Domestic Corporation, VEGAS
15 STRONGER, a Nevada Non-Profit
Corporation, MARLON PROFESSIONAL
16 CORPORATION, A Nevada Domestic
17 Professional Corporation, BIG E, A Nevada
Domestic Corporation, MOOREA
18 HOLDINGS, LLC, A Nevada Domestic
Corporation,
19 DOES I -X; ROE CORPORATIONS I -X.
20
Defendant.
21
22 The Plaintiff Gahyne Doahe (“Doahe”) by and through her attorney, Jenny L. Foley,
23 Ph.D., Esq. of HKM Employment Attorneys LLP hereby complains and alleges as follows:
24
PARTIES
25
1. Plaintiff, GAHYNE DOAHE (“Doahe”), was at all times relevant herein, a
26
resident of Clark County, Nevada.
27
28 2. Plaintiff is the victim of sexual assault, sexual harassment, and other violations

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Case Number: A-21-844132-C

 1 and as such, brings this Complaint under the fictitious name of “Gahyne Doahe” to protect her
2 privacy.
3 3. Relative to the allegations contained herein, Plaintiff filed an inquiry with the
4 Equal Opportunity Employment Commission (“EEOC”) to vindicate her rights under Title VII
5 of the Civil Rights Act of 1964, 42 U.S.C. Sect. 2000 et. seq.
6 4. Plaintiff reserves the right to amend this Complaint and/or file a separate
7 Complaint in Federal Court to vindicate her rights under Federal Civil Rights Statutes once her
8 administrative remedy is exhausted.
9 5. Upon information and belief, Defendant, David Marlon (“Marlon”) was at all
10 times relevant herein, a resident of Clark County, Nevada.
11 6. Upon information and belief, Defendant, John Seeland (“Seeland”) was at all
12 times relevant herein, a resident of Clark County, Nevada.
13 7. Upon information and belief, Crossroads of Southern Nevada is a Nevada
14 Expired Corporation.
15 8. Upon information and belief, Crossroads of Southern Nevada (“Crossroads”) at
16 all relevant times herein did business in Nevada as a drug and/or alcohol detoxification and
17 rehabilitation facility in Clark County, Nevada.
18 9. Upon information and belief, Vegas Stronger (“Vegas Stronger”) is an active
19 Domestic Nonprofit Corporation, doing business at all relevant times in Clark County, Nevada.
20 10. Upon information and belief, Marlon Professional Corporation (“MPC”) is a
21 Nevada Domestic Professional Corporation, doing business at all relevant times in Clark
22 County, Nevada.
23 11. Upon information and belief, Big E (“Big E”), an unknown corporation, doing
24 business at all relevant times in Clark County, Nevada.
25 12. Upon information and belief, Moorea Holdings A Nevada Domestic
26 Corporation, (“Moorea”) was, at all relevant times, doing business in Clark County, Nevada.
27 13. The exact inter-relationship between the various corporate entities and other
28 Defendants is unknown at this time.
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 1 14. The true names or capacities, whether individual, corporate, association or
2 otherwise, of Defendants, Does I through Does X, and Roe Corporation I through Roe
3 Corporations X, are unknown to Plaintiff, who therefore sues said Defendants by such fictitious
4 names. Plaintiff is informed and believe and therefore allege that each of the said Defendants
5 designated herein as Doe and Roe Corporation are responsible in some manner for the events
6 and happenings referred to and caused damages proximately to Plaintiffs as herein alleged, and
7 that Plaintiff will ask leave of this Court to amend this Complaint, to insert the true names and
8 capacities of Does I through Doe X and Roe Corporations I through Roe Corporations X, when
9 the same have been ascertained and to join such Defendants in this action.
10 JURISDICTION AND VENUE
11 15. This Court has subject matter jurisdiction over this action pursuant to Article 6,
12 §6 of the Nevada Constitution.
13 16. This Court has personal jurisdiction over Defendants because each has
14 continuous and systematic contacts with the State of Nevada; and upon information and belief,
15 each maintains his primary residence and is a citizen of Nevada and lives in Clark County and/or
16 regularly conducts business in Las Vegas, Nevada and committed the acts and omissions
17 described in Plaintiff’s underlying compliant in this judicial district.
18 17. Venue is proper in this Court pursuant to Nevada Revised Statute § 13.040
19 because the Defendants reside and conduct business here and Plaintiff’s claims arose in this
20 judicial district.
21 GENERAL ALLEGATIONS
22 DEFENDANT DAVID MARLON
23 18. Marlon holds himself out to be a “Psychotherapist,” and a licensed Drug and
24 Alcohol Counselor-Supervisor.
25 19. Upon information and belief, to the extent Marlon is a “Psychotherapist”
26 Plaintiff believes Marlon is not licensed as such anywhere on planet Earth.
27 20. Upon information and belief, Marlon is the CEO of Crossroads of Southern
28
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 1 Nevada, a for-profit corporation that bills itself as “Southern Nevada’s Top Drug and Alcohol
2 Addiction Treatment Center.”
3 21. Marlon is also the co-founder and chairman of Vegas Stronger, “a Las Vegas
4 non-profit committed to helping the most under-served in our community by addressing mental
5 health, substance use disorders and getting back to a healthy productive life.”1
6 22. Upon information and belief, Marlon is the CEO of Marlon Professional
7 Corporation and Moorea Holdings, LLC, both of which, upon information and belief, are inter-
8 connected somehow to Vegas Stronger and/or Crossroads.
9 23. Upon information and belief Marlon is also the CEO of a consulting company,
10 the Marlon Professional Corporation and works with several behavioral treatment centers,
11 helping them build their substance abuse programs.
12 24. Upon information and belief, Marlon was formerly the “President and co-
13 founder of Solutions Recovery, Inc., a Joint Commission accredited alcohol and drug treatment
14 center.”2
15 25. Marlon is or was also one of the interventionists on A&E’s television program,
16 “Intervention.”
17 26. Marlon is “deeply involved in working with recovering addicts and serves on
18 the Governors Substance Abuse Working Group, the Governor’s Rural Meth Action Team, the
19 Board of Directors for HELP of Southern Nevada, the Board of Directors for the 10,000 Kids
20 Foundation, the Las Vegas Rescue Mission, the Nevada Donor Network as well as the President
21 of (SNAAP), State of Nevada Association for Addiction Professionals.”3
22 27. Marlon is an active Nevada Amateur boxer, an avid mountain climber and
23 triathlete.4
24 VEGAS STRONGER
25
26
1
https://crossroadsofsonv.com/project/dave-marlon-ceo/
27 2
Id.
3
Id.
28 4
Id.

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 1 28. Upon information and belief, Vegas Stronger is organized as a non-profit
2 organization.
3 29. Vegas Stronger’s website states that their mission is “Utilizing our network of
4 community partners, Vegas Stronger will unite medication, therapeutic treatment, case
5 management, housing and work training, along with a wide variety of social services to create
6 an effective web we are certain will greatly diminish detrimental impacts from the opioid
7 epidemic.”
8 CROSSROADS OF SOUTHERN NEVADA
9 30. The Crossroads of Southern Nevada website states that “The Vegas Stronger
10 team joined Crossroads in January of 2020 to help address the mismanagement of the company
11 and bring back the operation from near bankruptcy.”5
12 31. Crossroads of Southern Nevada’s website states that it is a “detox facility for a
13 whole diverse set of people: court-ordered, parole, hospital referrals. We take all insurances
14 and even the uninsured. We also have a 90-day program. Sober living with intensive outpatient
15 programs to help them transition back into the community.”
16 DEFENDANT JOHN SEELAND
17 32. Defendant John Seeland is the Chief Operations Officer of Crossroads.
18 33. Defendant John Seeland is the Vice Chair and Board Member of Vegas Stronger.
19 34. Upon information and belief, Seeland is also involved in some way with Moorea
20 Holdings and/or Marlon Professional Corporation and/or Big E.
21 35. Upon information and belief, Seeland acts as the human resources person for
22 Vegas Stronger.
23 36. Upon information and belief, Codi Weaver is the human resources person for
24 Crossroads.
25 37. Seeland completed Plaintiff’s onboarding, and Weaver issued Plaintiff’s badge
26 for Crossroads and upon information and belief, maintains Plaintiff’s personnel file.
27
28 5
Id.

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 1 PLAINTIFF GAHYNE DOAHE
2 38. Plaintiff is a recovering alcoholic and drug addict.
3 39. Plaintiff’s sobriety has been a hard-won fight which Plaintiff continues to
4 engage through a variety of means, including attending meetings for recovering alcoholics and
5 drug addicts, ensuring that she avoids things that in the past would have led to her drinking and
6 or using drugs, and relevant here, ensuring that she found employment in an industry that would
7 support her in her ongoing clean/sober journey.
8 40. Plaintiff is very active in-service work such as sponsoring newcomers, chairing
9 meetings, visiting hospitals and institutions to share her story of recovery to patients in
10 treatment and volunteering to handle shifts taking calls on an Alcoholics Anonymous hotline.
11 PLAINTIFF’S RECOVERY THROUGH MARLON’S CORPORATIONS
12 41. Defendant David Marlon and Plaintiff became acquainted several years ago
13 when Plaintiff was engaged to Marlon’s cousin.
14 42. Due to his erratic behavior, his willingness to use steroids and testosterone, and
15 based on statements Marlon made to Plaintiff, Plaintiff believes that Marlon continues to abuse
16 drugs despite his public persona as a person deeply engaged in addiction recovery.
17 43. Plaintiff made numerous attempts to recover and rehabilitate from addiction and
18 continues to actively engage in behaviors to ensure she does not relapse again.
19 44. Plaintiff has been a client of Marlon’s various recovery centers several times
20 over the past several years.
21 45. Plaintiff was previously a patient at Crossroads.
22 46. Further Plaintiff previously attended rehab/detox at other facilities under
23 Marlon’s leadership, including but not limited to Solutions, which upon information and belief,
24 Marlon later sold to American Addiction Centers after allegations arose that Patient care was
25 lacking when at least one patient died.
26 47. On more than one occasion, Marlon made alternate payment arrangements for
27 Plaintiff to attend one or more of his detox/rehab programs.
28 48. Thus, Marlon was aware when he offered the job at issue to Plaintiff, that
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 1 Plaintiff was in dire financial straits, because Plaintiff specifically told him so.
2 PLAINTIFF’S EMPLOYMENT WITH MARLON AND MARLON
3 OWNED/OPERATED CORPORATIONS
4 49. In early April 2021, facing financial disaster after her husband moved to Florida,
5 Plaintiff contacted Marlon, someone she’d known for a long time, to request a job.
6 50. Plaintiff contacted Marlon specifically because she was aware that Marlon was
7 also in recovery and worked in the recovery field.
8 51. Plaintiff thought that she would be safe working for someone else who had been
9 through addiction and had seemingly dedicated his life to helping others recover from the
10 devastation wrought by addiction.
11 52. Marlon was aware that Plaintiff was in desperate need of a job and took
12 advantage of this for his own twisted sexual and emotional gratification.
13 53. Marlon offered Plaintiff a job as his personal assistant.
14 54. Marlon initially offered Plaintiff to continue to collect unemployment, stay on
15 Medicaid and he would pay her ‘off the books.’
16 55. Plaintiff declined Marlon’s offer as she was aware that accepting his offer would
17 be criminal fraud.
18 56. Upon information and belief, this is not the first time that Marlon has made, or
19 offered to make, such arrangements with his employees.
20 57. Marlon agreed to pay Plaintiff a yearly salary of $60,000 and told Plaintiff she
21 would receive a performance review on July 19, 2021 (the end of her probation period) and,
22 provided she performed well in her job duties, she would receive a raise.
23 58. Plaintiff began working for Marlon and various of Marlon’s owned/operated
24 corporate entities on or about April 19, 2021.
25 59. Plaintiff was jointly employed by Marlon, Vegas Stronger and/or Crossroads of
26 Southern Nevada and/or Moorea and/or MPC and/or Big E.
27 60. Plaintiff’s paycheck was issued from Vegas Stronger, however, most of her
28 badges, credentials and other indicia of employment were connected to Crossroads.
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 1 61. Further, Plaintiff performed numerous duties on behalf of MPC, Big E and
2 Moorea during her employment such that an exact determination of a single employer is
3 impossible.
4 62. Marlon was Plaintiff’s direct supervisor at all relevant times.
5 63. Throughout her employment, Marlon subjected Plaintiff to numerous acts of
6 sexual violence, physical violence, mental torture, harassment, humiliation, retaliation, threats,
7 and fear such that listing every instance of the same would be impossible.
8 64. Further, others in the various corporations were aware of the ongoing treatment
9 of Plaintiff and did nothing to stop Marlon’s behavior or protect Plaintiff, even going as far as
10 to cooperate with Marlon so he could continue to threaten Plaintiff after she complained to the
11 EEOC and filed a police report.
12 MARLON’S SEXUAL ADVANCES BEGIN ON PLAINTIFF’S FIRST DAY
13 65. On Plaintiff’s first day of employment, Defendant Marlon made the comment,
14 via text message, to Plaintiff that she “came dangerously close to being brutally raped with
15 your face pushed into the desk on your first day of work.”
16 66. Marlon also verbally told Plaintiff that he used to “jack off” to thoughts of her
17 when Plaintiff was engaged to Marlon’s cousin.
18 67. Marlon then asked Plaintiff if it would be all right with her if he held her hand
19 sometimes while they worked.
20 68. Plaintiff brought grapefruit to work for lunch on her first day.
21 69. Marlon, on the day in question, demanded that Plaintiff feed him a piece of the
22 grapefruit with her fork.
23 70. Marlon knelt on the floor on his hands and knees, by Plaintiff’s desk while
24 making this request.
25 71. Little did Plaintiff know that this type of behavior by Marlon would escalate and
26 continue.
27 72. Plaintiff thought these behaviors bizarre and disturbing, but as she was in
28 desperate need of the job, she convinced herself that Marlon’s behavior would get better.
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 1 73. It was obvious to Plaintiff that if she demurred in any of Marlon’s requests, that
2 she would lose her job.
3 74. Defendant’s sexually oriented demands continued.
4 MARLON DEMANDS PLAINTIFF DRESS IN CERTAIN WAYS
5 75. Within two weeks of starting, Marlon demanded that Plaintiff purchase certain
6 clothing, shoes, and sex toys, for which he reimbursed her.
7 76. Thereafter, Marlon began to insist that Plaintiff wear certain of the clothing and
8 shoes.
9 MARLON DEMANDS PLAINTIFF PICK UP HIS STEROID AND SILDENAFIL
10 PRESCRIPTIONS
11 77. Also, shortly after Plaintiff began her employment, Marlon required her to fill
12 and/or pick up various prescriptions for him including Human Growth Hormone, Testosterone,
13 Stanozolol (Winstrol), and Sildenafil (Cialis).
14 78. Plaintiff believed that the combination of the testosterone and steroids made
15 Marlon even more physically and sexually aggressive toward her.
16 79. Picking up Marlon’s prescriptions was not in any of the job duties Plaintiff had
17 agreed to accept.
18 MARLON BEGINS SPANKING PLAINTIFF
19 80. Shortly after she began working, Marlon expanded Plaintiff’s job duties such
20 that upon his command, she was to take a certain pose.
21 81. When Marlon instructed Plaintiff to “assume the position,” she was to stand with
22 her legs shoulder width apart, with her hands on a desk, table, or, if nothing else was available,
23 a wall.
24 82. Plaintiff was required to arch her back so that her bottom stuck out.
25 83. Shortly thereafter, Marlon began striking Plaintiff’s buttocks with his hand when
26 he would instruct her to “assume the position.”
27 84. Plaintiff believes that the combination of steroids, testosterone and other
28 medications made Marlon even more aggressive and forceful.
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 1 MARLON’S SEXUAL BEHAVIOR EXPANDS TO MARKING PLAINTIFF WITH A
2 PADDLE - LEAVING THE WORD “SLUT” BRUISED INTO HER SKIN
3 85. Unhappy with merely striking Plaintiff with his hand, Marlon also directed
4 Plaintiff to purchase a paddle with raised lettering that had the word “Slut” or “Whore.”
5 86. Thereafter, Marlon reimbursed Plaintiff in cash for the purchase of the paddle.
6 87. Further, at various times, Marlon instructed Plaintiff to purchase other sex toys
7 and/or clothing and thereafter, Marlon would reimburse Plaintiff in cash.
8 88. Marlon informed Plaintiff that the purpose of the raised lettering was so that
9 Plaintiff would be “branded” (bruised) when Defendant Marlon hit her with the paddle.
10 89. Defendant Marlon would, usually at least once per day, require that Plaintiff
11 “assume the position.”
12 MARLON’S SEXUAL VIOLENCE PROGRESSES TO THE USE OF WHIPS,
13 PADDLES AND A RIDING CROP
14 90. The spankings progressed from Defendant Marlon using his hand, to use of
15 various implements, including, but not limited to whips, paddles (including the “Slut” paddle),
16 and eventually a riding crop.
17 91. A riding crop is an implement, typically made of leather, which is used to strike
18 a horse for discipline.
19 92. The use of riding crops is frowned upon by many equestrians as being too brutal
20 for horses, which often weigh more than 850 lbs.
21 93. On or about April 27, 2021, Plaintiff was distraught because her husband was
22 moving to Florida, and she was fearful of being alone for the first time in her life.
23 94. Defendant Marlon kissed Plaintiff on the mouth, putting his tongue in her mouth,
24 and told her that he loved her and that if she stayed sober, he would always take care of her.
25 MARLON REQUIRES PLAINTIFF’S COOPERATION TO DECEIVE HIS WIFE
26 95. In a bizarre twist, on or about May 5, 2021, Marlon told Plaintiff that she would
27 have to drive herself to Allegiant Stadium for a Commissioner’s Reception because Marlon’s
28 wife did not permit him to be alone in a vehicle with another women.
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 1 96. Marlon explained that due to his previous extramarital affairs, which Plaintiff
2 later determined also included previous accusations of sexual harassment from Marlon’s
3 personal assistants, that his wife did not permit him to be alone in any context with another
4 woman without her being present.
5 97. Later, Plaintiff became suspicious that part of the reason for this prohibition
6 from Marlon’s wife was that Marlon could not be trusted to refrain from engaging in sexually
7 aggressive behavior with women he finds attractive.
8 MARLON REVEALS HE IS A “SWITCH”
9 98. On or about May 5, 2021, Marlon explained to Plaintiff that he is a “Switch.”
10 99. Plaintiff googled the term to find out the definition of a “Switch.”
11 100. Plaintiff discovered that “Switch” is a BDSM lifestyle term for a person who
12 takes the dominant role in a relationship at times and at others, a submissive role.
13 101. This became relevant when Marlon later expanded the requirements of
14 Plaintiff’s job duties.
15 MARLON THREATENS PLAINTIFF WITH TERMINATION, OR A “NUCLEAR
16 OPTION” IF HIS WIFE DISCOVERS HIS INFIDELITY
17 102. Defendant Marlon explained to Plaintiff, via text message on or about May 5,
18 2021, that there are “Two scenarios if we are discovered: 1: Nuclear option 2: a demand for
19 immediate and permanent separation.”
20 103. Plaintiff had been terrified that her job she would lose her job if she did not
21 comply with Marlon’s’ sexual demands and remained more so after this text message.
22 104. Further, Plaintiff began to become concerned for her physical safety (separate
23 and apart from her ongoing fear of physical/sexual assault by Marlon) when Marlon threatened
24 a “nuclear” option if his wife were to discover their activities.
25 105. On or about May 6, 2021, Marlon instructed Plaintiff to give John J. a tour of
26 the Crossroads of Southern Nevada rehab facility.
27 106. Later, Marlon would insist that Plaintiff “be the slut you are” and have sex with
28 John J.
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 1 107. On the same day, Marlon’s wife discovered that Plaintiff worked for Defendants.
2 108. Marlon informed Plaintiff that he lied to his wife and told his wife that Plaintiff
3 worked in a different office building than the one in which he primarily worked.
4 109. In fact, prior to that date, and continuing thereafter, Marlon insisted that Plaintiff
5 work in the same physical office with him, working mere feet from Marlon.
6 MARLON TAKES PHOTOGRAPHS OF PLAINTIFF’S BRUISED BOTTOM
7 110. On or about May 10, 2021, for the first time, Marlon used the “Slut” paddle on
8 Plaintiff, causing her to be bruised with the word “Slut” on her buttocks.
9 111. Marlon increased Plaintiff’s humiliation by taking photographs of her buttocks
10 with her phone.
11 112. On at least one occasion, Marlon took photographs of Plaintiff’s bruises with his
12 own phone.
13 113. Plaintiff does not know if Marlon kept copies of the photographs or if he sent
14 the photographs to anyone else.
15 114. Marlon engaged in this behavior on more than one occasion after he struck her,
16 either with his hand or with some other implement.
17 MARLON’S THREATS ESCALATE
18 115. Marlon informed Plaintiff via text message that “the severity of repeated
19 punishments will be determined by [her] obedience.”
20 116. Thereafter, Plaintiff received a text message from Marlon stating, “There are
21 two Dave’s… nice Dave and brutal Dave?”
22 117. The message contained a photograph of Marlon in a suit, and a photograph of
23 some very muscular man in a white tank top, in an aggressive pose with his hair decidedly
24 unkempt (possibly Marlon).
25 118. The threat was clear, if Plaintiff demurred, sought help, or otherwise failed to
26 obey Marlon’s every sexual demand, she would be at least physically brutalized, and
27 terminated.
28 ///
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 1 MARLON RAPES PLAINTIFF- THE FIRST TIME
2 119. On or about May 10, 2021, Marlon instructed Plaintiff to get the keys for an
3 empty office building from another employee.
4 120. Marlon and Plaintiff had intercourse in the Crossroads office on Shadow Lane
5 the same day.
6 121. Marlon insisted on unlocking the office door, thereby increasing the possibility
7 of being caught and causing enormous humiliation and anxiety to Plaintiff.
8 MARLON’S BIZARRE SEXUAL DEMANDS ESCALATE
9 122. On or about May 11, 2021, Marlon instructed Plaintiff to purchase a remote-
10 controlled vibrator.
11 123. Further, Marlon told Plaintiff she could take time off work if she had intercourse
12 with other men, then returned to the office and perform certain acts to ‘prove’ she’d had
13 intercourse.
14 124. Marlon required Plaintiff to prove she’d had intercourse with other men by
15 inserting her fingers into her vagina and feeding him the semen left by other men.
16 125. Marlon stated specifically that he wanted Plaintiff to feed him semen from
17 Plaintiff’s vagina, off her fingers, “like a dog.”
18 126. The specifics of the request horrified Plaintiff.
19 127. However, throughout her tenure, Plaintiff learned that when she would comply
20 with such requests from Marlon, he would temporarily refrain from beating her and/or the
21 beatings would be milder in nature.
22 MARLON DEMANDS PLAINTIFF SIGN A “CONTRACT”
23 128. A day or two after Marlon insisted Plaintiff “prove” she’d had intercourse with
24 other men, Marlon dictated a letter to Plaintiff, via text message, that he later insisted that she
25 sign.
26 129. The text message stated in relevant part “draft our understanding please.”
27 130. Plaintiff’s response was “will need some guidance with that please. I have zero
28 experience with contracts. If we could discuss briefly at some point today, I would appreciate
Page 13 of 40
 1 it. I will get started ASAP.”
2 131. Marlon’s response was “Ha. Not really a contract. [Gahyne] craves discipline
3 and punishment. She welcomes integration of work and mental ‘Games.’ At any point [Gahyne]
4 wants to stop, she will tell Dave and relationship will become solely a work relationship. We
5 both understand that disclosure will cause other significant pain and trouble and neither wants
6 that to ever happen, ever.”
7 132. Plaintiff understood Marlon’s reference to “significant pain and trouble” to
8 mean possible further physical repercussions/beatings/assaults and/or termination of her job.
9 133. Shortly after Marlon dictated the text of the “contract” he required Plaintiff to
10 sign, Marlon approached Plaintiff at the office and insisted that she modify the document to
11 include a reference to her desire to be raped by multiple men.
12 134. At various points during her employment, Marlon would threaten Plaintiff with
13 gang rape if she failed to please him.
14 135. Among the various scenarios proposed by Marlon included himself and a friend
15 of his, who is an anesthesiologist, raping Plaintiff in various ways.
16 136. The threats involving the anesthesiologist included threats of anal rape,
17 blindfolds, kicking Plaintiff and making Plaintiff scream in pain.
18 137. Marlon stated that he and his anesthesiologist friend had previously engaged in
19 this type of behavior, which lent credence to his threat and served to terrify Plaintiff even
20 further.
21 138. Marlon also confirmed that such behavior between himself and his friend
22 involved Marlon’s previous executive assistant when Marlon was the CFO of Sierra Health.
23 139. Plaintiff believes that this previous behavior between Marlon and the
24 anesthesiologist prompted Marlon to insert the change into the document.
25 140. Plaintiff quite definitely had no desire to be raped by anyone, let alone multiple
26 men.
27 141. Further, Marlon made clear that the homeless men he hired to empty out the
28 space planned to be offices for Vegas Stronger, were on the list of possible rapists.
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 1 142. However, in fear for her job, and her physical safety if she did not comply,
2 Plaintiff did as ordered and made the change.
3 143. Before she printed the document, to try to protect herself, Plaintiff inserted a
4 phrase indicating that if she wanted to stop the relationship that she would not be terminated.
5 144. Thereafter, Plaintiff told Marlon she did not want to continue the relationship.
6 145. Marlon and Plaintiff each signed the document (Exhibit A).
7 146. Plaintiff believes that to hide indisputable proof of his extramarital affair and the
8 harassment and coercion he exercised against his employee, Marlon then instructed Plaintiff to
9 destroy the document.
10 MARLON THREATENS TO WHIP PLAINTIFF AT CROSSROADS
11 147. On or about May 11, 2021, Marlon texted Plaintiff stating that he would whip
12 her so hard that there would be welts and that he would cum inside her before leaving her in a
13 wilted pile on the group room floor.
14 148. The group room to which the text referred was the group therapy room at
15 Crossroads of Southern Nevada.
16 PLAINTIFF DISCOVERS MARLON’S HISTORY OF TARGETING PREVIOUS
17 PATIENTS OF HIS RECOVERY CENTERS FOR HIS SEXUAL GRATIFICATION
18 149. Marlon insisted on or about May 14, 2021, that Plaintiff drive with him to a
19 pharmacy.
20 150. On the way to the Pharmacy, Defendant kissed Plaintiff and told her how happy
21 he was that he was loyal to only two women, to Plaintiff and his wife.
22 151. Shocked, Plaintiff asked if Defendant had done “this” meaning the extramarital
23 affair and the ongoing sexual harassment, sexual assault, and threats of retaliation with other
24 women at work.
25 152. Defendant denied having done so.
26 153. However, Plaintiff later discovered that, upon information and belief, Defendant
27 Marlon has a history of sexually harassing women who he either employs or provides funds to
28 via an app called “Venmo.”
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 1 154. Upon information and belief, Marlon makes a point to prey on women who are
2 in recovery for drug and/or alcohol addiction.
3 155. Plaintiff also discovered that, upon information and belief, Marlon has a history
4 of using his position to sexually abuse/exploit women who are in recovery and come to him/his
5 company for rehabilitation and help with addiction.
6 MARLON ONCE AGAIN REQUIRES PLAINTIFF TO DECEIVE HIS WIFE
7 156. On or about May 13, 2021, Defendant Marlon was in a panic that his wife had
8 discovered, through an app on her personal computer, that Marlon was not where he’d told his
9 wife he would be.
10 157. Marlon told Plaintiff she had to pack up and leave the office immediately
11 because his wife was coming to the office because he’d been caught in a lie.
12 158. Plaintiff believed that the lie involved his whereabouts earlier in the day when
13 she had picked up Marlon from dropping off his car to have the bumper painted.
14 159. Marlon then told Plaintiff that if his wife knew she had been in his vehicle, that
15 he would be forced to fire Plaintiff.
16 160. Shocked and terrified of losing her only source of financial support (her job) and
17 seeing a potential opportunity to make the near daily beatings and unwelcome sexual activities
18 stop, Plaintiff asked for a transfer to another building.
19 161. Marlon said that wasn’t possible and reiterated again, that if his wife found out
20 (presumably that Plaintiff worked with Marlon and/or that Marlon was sexually assaulting
21 and/or harassing Plaintiff) that Plaintiff would be summarily terminated.
22 162. A couple of days later, Marlon came to the office without his cell phone,
23 explaining that his wife had confiscated his phone to go through his text messages and pictures.
24 163. Others in the office were aware of this including Nicole Christie, James Payne.
25 164. The group made jokes regarding Marlon’s proclivity to garner sexual
26 harassment and/or infidelity accusations, the most recent of which was an accusation made by
27
28
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 1 Marlon’s previous executive assistant.6
2 165. Marlon joked that Plaintiff was concerned she would be fired for giving Marlon
3 a ride, thereby violating his wife’s rules.
4 166. Payne then turned to Plaintiff and stated “as long as you don’t sleep with Dave,
5 your job is fine” or words to that effect.
6 167. Knowing what happened to the last woman who complained of being sexually
7 harassed by Marlon, Plaintiff grew even more concerned that Marlon would terminate her.
8 PLAINTIFF CONTACTS A SEXUAL ASSAULT SUPPORT HOTLINE
9 168. On or about May 18, 2021, Plaintiff made the first of two phone calls to a sexual
10 assault support hotline, RAINN.
11 169. Plaintiff spoke with an advocate for approximately an hour starting at around
12 5:20 AM that morning.
13 MARLON MANUFACTURES EXCUSES TO BEAT PLAINTIFF
14 170. On or about May 20, 2021, just a few days after Marlon became frightened his
15 wife would find out about his nefarious activities, Marlon accused Plaintiff of forgetting to tell
16 Marlon about a meeting with the CEO of Spring Mountain Hospital.
17 171. Thereafter, Marlon beat Plaintiff with the “Slut” paddle, ensuring that her
18 buttocks were thoroughly and severely bruised.
19 172. Marlon made it clear that this beating was in retaliation for her alleged failure to
20 do her job correctly.
21 173. Later, Marlon expressed to Plaintiff that he enjoyed setting her up to fail in her
22 duties, so he would have an excuse to beat her and/or rape her.
23 174. On or about May 26, Marlon instructed Plaintiff to pick up a steroid prescription
24 for Marlon so he could begin preparing for a fight.
25 175. Upon information and belief, Marlon participates in amateur boxing.
26 176. This information terrified Plaintiff because it meant that Marlon would be even
27
28 6
Name withheld for privacy

Page 17 of 40
 1 more aggressive and physically violent.
2 MARLON BEGINS USING A “BURNER” PHONE TO COMMUNICATE
3 177. Thereafter, Marlon instructed Plaintiff to purchase a ‘burner’ phone, for which
4 he reimbursed her, which he instructed to her to take home and charge every night and bring to
5 work with her every morning.
6 178. The purpose of the “burner” phone was so that Marlon could communicate with
7 Plaintiff while at work without the possibility his wife would discover his misdeeds.
8 MARLON’S WIFE FINDS OUT ABOUT HIS PREVIOUS SEXUAL HARRASMENT
9 OF OTHER WOMEN IN RECOVERY
10 179. Shortly after her employment began, Plaintiff discovered that Marlon’s wife had
11 forbidden him to have any communication with females, and that she must accompany him to
12 all business meetings and had re-iterated her rule that he never be alone with any female even
13 for business purposes.
14 180. Marlon explained to Plaintiff that his wife had found out about the sexual
15 harassment allegations from Marlon’s previous subordinate.
16 181. Marlon explained that the woman was never his employee, because he would
17 pay her via Venmo and had instructed the woman to continue to file for and accept
18 unemployment assistance and Medicaid.
19 182. Further, he needed the burner phone because his wife was getting copies of all
20 his incoming and outgoing texts.
21 183. Marlon was out of town from May 28-May 31, 2021, giving Plaintiff some
22 respite.
23 184. Thereafter, he texted Plaintiff stating that he ‘went crazy’ not being able to
24 communicate with her and that he had never ‘jacked off’ so much.
25 MARLON BEATS PLAINTFF, THEN THREATENS TO CHOKE HER
26 UNCONCSIOUS AND KICK HER UNCONSCIOUS BODY IF SHE RESISTS AS
27 RETALIATION FOR HER REFUSAL TO PURCHASE ALCOHOL
28 185. On or about June 1, 2021, Marlon instructed Plaintiff to invite his neighbor to a
Page 18 of 40
 1 men’s ‘whiskey and cigar event’ to discuss spirituality on June 3, 2021, at his home.
2 186. Marlon instructed Plaintiff that she was to ensure that one specific neighbor
3 knew the evening would include “blow and whores.”
4 187. Before her employment with Marlon, Marlon indicated to Plaintiff had he kept
5 cocaine in the safe at his home.
6 188. At one point, Marlon stated that his ex-wife (or soon to be ex-wife) had broken
7 into his safe, stolen a watch and took the cocaine that had been in the safe.
8 189. Plaintiff had always assumed that these statements were meant as jokes, albeit
9 in poor taste.
10 190. However, considering Marlon’s bizarre behavior, these statements began to
11 haunt Plaintiff.
12 191. Further, a member of Marlon’s family told Plaintiff that despite Marlon holding
13 himself out as having been clean and sober for many years that during that time, Marlon
14 attended rehab for a relapse in California at least twice, while continuing to claim that he had
15 been clean and sober the entire time.
16 192. Further, Plaintiff was informed that Andy H7, had suffered a relapse within
17 approximately the past year, because Andy, a good friend of Marlon’s, had found cocaine in
18 Marlon’s house and picked up.
19 193. Upon information and belief, on or about June 3, 2021, Marlon held a whiskey
20 and cigar meeting at his home with some men to discuss spirituality.
21 194. Despite his knowledge that Plaintiff was in recovery, shortly before the meeting,
22 Marlon instructed Plaintiff to purchase whiskey glasses and liquor for the meeting.
23 195. Plaintiff duly purchased the glasses.
24 196. Plaintiff objected to purchasing liquor because she was concerned that
25 purchasing alcohol would tempt her to relapse in her sobriety.
26 197. Because of this incident, Plaintiff grew concerned that Marlon was slipping in
27
28 7
Name changed to protect third party interests.

Page 19 of 40
 1 his recovery as she was aware of the violence and chaos that can ensue when someone ‘falls off
2 the wagon.’
3 198. In retaliation, Plaintiff was yet again told to “assume the position” at work.
4 199. Marlon gave this instruction to Plaintiff approximately one hour after Marlon
5 returned from marriage counseling.
6 200. Plaintiff did so because she did not want Marlon to fire her.
7 201. This time, however, during the beating, Marlon roughly, painfully, and
8 unexpectedly inserted several fingers into Plaintiff’s vagina with no lubrication, causing vaginal
9 tearing.
10 202. In response to the unexpected type of pain, Plaintiff squeezed her legs together
11 and lifted one leg to try to dislodge Marlon’s fingers.
12 203. In response, Marlon grabbed Plaintiff and choked her, telling her that if she ever
13 tried to resist him again, he would choke her to unconsciousness and then kick her after she fell
14 to the floor.
15 204. Up to this point, Plaintiff had endured Marlon’s bizarre behavior and sexual
16 harassment and sexual assaults because she had no other means of supporting herself without
17 the job, which she’d been told she would lose if she ever protested or resisted Marlon’s
18 unwelcome beatings and sexual commentary.
19 205. Marlon’s insertion of his fingers into her vagina, and his violent and terrifying
20 reaction when she protested finally made Plaintiff realize that Marlon was every bit as
21 dangerous as she feared him to be.
22 206. Plaintiff was too sore after the sexual assault to sit properly and requested
23 permission to go home for the day, which Marlon granted.
24 207. Before she left, Plaintiff stated to Marlon that per the terms of the “contract” that
25 she wanted to have a strictly work-based relationship with him.
26 208. Marlon’s response was a sarcastic “okay.”
27 209. Upon information and belief, the same day Marlon complained to “James” that
28 Plaintiff was not performing her job duties adequately.
Page 20 of 40
 1 210. When Plaintiff discovered this, she realized, yet again, that Marlon would stop
2 at nothing to get what he wanted from her.
3 MARLON USES HIS “PSYCHOTHERAPY” BACKGROUND TO MENTALLY
4 TORTURE PLAINITFF
5 211. In early June 2021, Maron instructed Plaintiff to buy a book entitled “I Thought
6 It Was Just Me.”
7 212. Marlon told her that the book involved the exploration of a person’s “shame.”
8 213. Marlon explained that in his research for his Ph.D., (which he is, upon
9 information and belief, in the process of obtaining from Walden University), he discovered that
10 “all submissives” have some source of shame which makes them submissive, usually centering
11 on early childhood sexual trauma.
12 214. Plaintiff explained that she is not a ‘submissive,’ nor had she had a bad
13 childhood.
14 215. Marlon insisted that Plaintiff buy and read the book so that he could explore the
15 sources of Plaintiff’s shame with her.
16 216. Marlon specifically noted that he wanted to know of what Plaintiff was ashamed,
17 so that he could use that information to further humiliate her for his own sexual gratification.
18 217. Plaintiff again explained that she had no desire for this type of interaction and in
19 any event, had not had a bad childhood.
20 218. Marlon told her that since he is the certified counselor, he knew better than she
21 did and nonetheless, they would be exploring this topic further.
22 MARLON INSISTS PLAINTIFF BEFRIEND HIS WIFE TO AVOID TERMINATION
23 219. In late May or early June 2021, Marlon instructed Plaintiff to contact his wife
24 via Facebook and try to befriend his wife so that he wouldn’t ‘have to’ fire her.
25 220. Plaintiff did as instructed.
26 MARLON’S SEXUAL DEMANDS ESCALATE
27 221. On or about June 9, 2021, Marlon sent Plaintiff a text informing her that one of
28 her new duties was to orally clean his “cock”, every time it came out of her “whore hole.”
Page 21 of 40
 1 222. Marlon’s reference to Plaintiff’s ‘whore hole’ meant her vagina.
2 MARLON INSISTS PLAINTIFF IS HIS “PROPERTY”
3 223. On or about June 10, 2021, Marlon sent a text message to Plaintiff stating “you
4 need to come to terms with the fact that you are my property. You serve me at all times, even
5 when I have you whoring. I make all decisions for you.”
6 224. On the same day, Marlon ordered Plaintiff to return to the office after business
7 hours so that she could yet again engage in sexual acts that satisfied his “switch” tendencies.
8 225. However, after she had done so, Plaintiff again noticed that Marlon was less
9 violent and aggressive for a few days.
10 MARLON VIOLENTLY RAPES PLAINTIFF AFTER SHE TELLS HIM SHE IS
11 CLOSE TO DRINKING AGAIN BECAUSE OF HIS SEXUAL DEMANDS
12 226. On or about June 11, 2021, Marlon called Plaintiff, surprising her, and
13 mentioned that she seemed more distant than usual and assured her that he was quite happy
14 with the job she was doing.
15 227. Plaintiff explained that due to their relationship, she was on the verge of
16 drinking.
17 228. In response to her statement, on or about June 13, 2021, Marlon emailed plaintiff
18 instructing her to meet him at the Crossroads office to “review web proposals.”
19 229. Despite it being her day off, Plaintiff complied, hopeful that Marlon heard and
20 understood her requests to have a work only relationship, perhaps because she told Marlon she
21 was on the verge of drinking, he would stop his sexual demands.
22 230. Marlon did not stop.
23 231. After meeting Plaintiff at the Crossroads office that day, Marlon was surprised
24 to see John Seeland in the office.
25 232. Thereafter, Marlon instructed Plaintiff to go to the Vegas Stronger office on
26 Main Street in Las Vegas.
27 233. The office at that time was a vacant warehouse, still under construction.
28 234. When she arrived, Marlon bent Plaintiff over a table and raped her.
Page 22 of 40
 1 235. Plaintiff cried and begged him to stop.
2 236. Marlon did not stop, and in fact, escalated the brutal assault by continually
3 striking Plaintiff’s buttocks, causing bruising.
4 237. It was not the first time Marlon bruised Plaintiff with his sexual attentions, nor,
5 unfortunately, the last time Marlon would rape Plaintiff.
6 238. Marlon beat Plaintiff harder for telling him to stop and for crying.
7 239. Marlon also informed plaintiff that she was going to be beat for making noise
8 because she was supposed to suffer like a good whore.
9 240. After he finished, Marlon forced Plaintiff to her knees and forced his penis into
10 her mouth, telling her to clean his cock.
11 241. Despite his threats, Plaintiff again stated that she did not enjoy the pain he was
12 inflicting and wanted the sexual activity to stop.
13 JOHN STUART RABON FINDS OUT ABOUT
14 MARLON’S SEXUAL PROCLIVITIES
15 242. On or about June 14, 2021, Marlon called Plaintiff.
16 243. Plaintiff put the call on speakerphone when she answered.
17 244. Marlon addressed her stating, “good morning my seed receptacle.”
18 245. John Stuart Rabon, who, upon information and belief was the Data Analytics
19 Officer for Crossroads and/or Vegas Stronger overheard the comment.
20 246. In a later text exchange, Plaintiff confirmed to Rabon that “now you understand
21 my moods, sorry.”
22 247. Rabon responded “No worries!! All good. Let me know if I can help in any way.
23 Please don’t tell anyone (especially Dave) that I know.”
24 248. Rabon’s response, in addition to acknowledging his failure to report the sexual
25 harassment, indicated to Plaintiff that Rabon was both aware of Marlon’s proclivities and afraid
26 of retaliation by Marlon.
27 249. Plaintiff responded “John, he would fire me on the spot”
28 250. Rabon responded with a “thumbs up” emoji.
Page 23 of 40
 1 251. Plaintiff continued the text exchange stating, “not what I signed up for, for the
2 record.”
3 252. Later that day, Rabon came to the office and brought Plaintiff a Cannoli to
4 console her.
5 253. Other employees, including Chris Gordon, the (then) Community Outreach
6 Director for both Crossroads and Vegas Stronger, noticed that Marlon treated Plaintiff badly,
7 and confirmed the same to Plaintiff.
8 254. Plaintiff stated that “its not just talk.”
9 255. Gordon asked, “what do you mean, is he hurting you?”
10 256. Gordon’s statement indicated that he knew that Marlon had a proclivity of
11 violence toward women.
12 257. Terrified that Gordon, a very good friend of Marlon’s would tell Marlon that
13 she’d complained, Plaintiff stated that “it’s not just verbal abuse.”
14 258. On a number of other occasions, after Marlon would rape or beat Plaintiff in the
15 office, Gordon noticed that Plaintiff would be angry or glaring at Marlon and would make jokes
16 about Plaintiff’s inability to ‘hide’ her emotions.
17 259. In a similar vein, Gordon also failed to take any steps to address the ongoing
18 sexual harassment and assault and retaliation.
19 260. Plaintiff had numerous conversations with Nicole Christie, who had handled the
20 situation regarding Marlon’s previous sexual harassment accusation by Marlon’s previous
21 executive assistant, wherein Plaintiff complained that Marlon was aggressive and mean to her.
22 261. Christie, who had been instrumental in covering up the previous sexual
23 harassment accusations by Marlon’s previous executive assistants, made clear to Plaintiff that
24 while her loyalty was “always” to Marlon, that Plaintiff could reach out to her to discuss
25 anything.
26 262. Thereafter, Christie continued to make clear that her loyalty was to Marlon.
27 ///
28 ///
Page 24 of 40
 1 MARLON RAPES PLAINTIFF DURING A ZOOM BOARD MEETING OF THE
2 SOUTHERN NEVADA ASSOCIATION OF ADDICTION PROFESSIONALS
3 263. On or about June 15, Marlon called Plaintiff asking why she wasn’t at the Vegas
4 Stronger building for the SNAAP (Southern Nevada Association of Addiction Professionals)
5 board meeting.
6 264. Plaintiff replied that the meeting was via zoom, and she planned to attend from
7 the Crossroads office.
8 265. Marlon’s response was “get your slut ass here NOW, whore.”
9 266. When she arrived, Plaintiff was dismayed to realize she was alone with Marlon.
10 267. During the meeting, Marlon turned off his video and microphone and told her to
11 “assume the position.”
12 268. Plaintiff was particularly humiliated by this because the desk was situated close
13 to a window, with a junkyard visible.
14 269. Any one of the men who works in the junkyard could have passed by and seen
15 Marlon abusing her.
16 270. Thereafter, Marlon used a riding crop to beat Plaintiff.
17 271. Plaintiff cried and begged for him to stop.
18 272. She moved away from the riding crop and told him that she was in too much
19 pain and couldn’t tolerate the riding crop.
20 273. Marlon choked Plaintiff and told her to remember what he said he would do if
21 she resisted him.
22 274. Marlon ordered Plaintiff to assume the position again.
23 275. Terrified that Marlon would choke her unconscious and then kick her while
24 unconscious as he had previously threatened, Plaintiff complied.
25 276. Marlon then continued to hit Plaintiff with the riding crop.
26 277. Plaintiff was red and bruised from the beating.
27 278. Marlon was so pleased with his handiwork, he made Plaintiff pose for a series
28 of pictures, giving her specific instructions to arch her back, get on her tippy toes, spread her
Page 25 of 40
 1 legs, and tilt her head back more.
2 279. The board meeting ended approximately 30 minutes later.
3 280. Thereafter, Marlon instructed Plaintiff to pull her pants down to receive the
4 remainder of her punishment for telling him no.
5 281. Thereafter, he beat Plaintiff with his hand and repeated the process of taking
6 photographs.
7 282. When Marlon finished, Plaintiff went to the receptionist area at the front to pack
8 up her belongings.
9 283. Marlon cornered her in the cubicle and raped her.
10 284. Thereafter, Marlon forced Plaintiff to clean his penis with her mouth.
11 285. Finally finished, Marlon zipped up his pants and called Plaintiff the “best
12 receptionist ever.”
13 286. Angry, Plaintiff replied that she was not ‘a fucking receptionist.”
14 287. Marlon’s’ response was to say, “I’ll see you at Shadow Lane.”
15 MARLON RAPES PLAINTIFF IN THE GROUP THERAPY ROOM AT
16 CROSSROADS
17 288. On or about June 15, 2021, Marlon again raped Plaintiff.
18 289. This time the rape took place in the group therapy room at Crossroads, where
19 Marlon blocked the door with a chair.
20 290. On another occasion, while Marlon forced intercourse on Plaintiff, at some point
21 during the assault, someone (Plaintiff believes it may have been the carpet cleaner) entered the
22 room, and quickly closed the door to the group therapy room.
23 291. Plaintiff was humiliated to think that someone else may have seen her being
24 raped.
25 292. On or about June 17, 2021, the rape in the group therapy room was so brutal that
26 Plaintiff bled all over Marlon’s beige suit pants and white shirt.
27 293. On this occasion, Marlon apparently planned on being particularly brutal as he
28 ensured the door to the group therapy room was blocked before he attacked Plaintiff.
Page 26 of 40
 1 294. Plaintiff’s head repeatedly smacked against the wall as he inserted his penis into
2 her vagina.
3 295. When Marlon completed, seeing the blood, Plaintiff became terrified that
4 Marlon would beat her for bleeding on him because of his rape and apologized profusely saying
5 “I’m sorry, I’m so sorry.”
6 296. Marlon then insisted that Plaintiff clean his penis with her mouth.
7 297. Revolted, Plaintiff shook her head ‘no’ as she looked at her own blood on
8 Marlon’s penis.
9 298. Marlon looked down and saw the blood.
10 299. Thereafter, Marlon grabbed Plaintiff’s head and shoved his penis into Plaintiff’s
11 mouth, forcing her to lick her own blood from his penis.
12 300. Plaintiff was in tears and begged him to stop.
13 301. Once finished, Marlon instructed Plaintiff to get him a folder and his boxing
14 shorts.
15 302. She complied and Marlon changed clothes and then he left.
16 303. Plaintiff initiated her charge with the EEOC on this date.
17 MARLON THREATENS PLAINTIFF- AGAIN
18 304. Plaintiff called out of work on June 21, 2021, because she continued to bleed
19 due to the violent rape a few days prior, and her fear that she would again be sexually brutalized.
20 305. On June 22, 2021, Plaintiff went to work.
21 306. However, when Plaintiff discovered that she was the only person in the office,
22 she returned to her car to wait for someone else to arrive.
23 307. Shortly before 8 A.M., Marlon approached Plaintiff’s car and asked her to “name
24 your price, how much to make this go away.”
25 308. Upon information and belief, Marlon was referring to Plaintiff’s EEOC filing
26 which Plaintiff’s attorney provided to Marlon the previous day.
27 309. Plaintiff stated that she would be in the office after 8 A.M. when someone else
28 was in the office.
Page 27 of 40
 1 310. On or about June 22 ,2021 Plaintiff went to the hospital after the rape on June
2 20, 2021, to seek medical attention for her injuries.
3 PLAINTIFF REPORTS THE SEXUAL ABUSE TO JOHN SEELAND
4 311. Plaintiff reported the matter to John Seeland, who acts as the Human Resources
5 director for Crossroads and Vegas Stronger.
6 312. Plaintiff showed Seeland some of the photographs of her bruised buttocks taken
7 by Marlon after he’d abused her and stated, inter alia, “this is what happens when I am alone
8 with Dave. Please make sure I am not alone with him with the door closed.”
9 313. Seeland assured Plaintiff that would not happen.
10 314. Plaintiff later confirmed, in a text message with Seeland her request that: “I just
11 want to come to work and do my job and feel safe. Please ensure I am not alone, that’s all I
12 ask. I love the work I do.”
13 315. Seeland responded stating “You are A-OK by me [Gahyne]. No worries…”
14 SEELAND FACILITATES MARLON’S THREATS TO PLAINTIFF
15 316. Seeland’s office door is three inches from the office Marlon and Plaintiff shared.
16 317. On this occasion, another employee John Rabon was in the office that Marlon
17 and Plaintiff shared.
18 318. Approximately 20 minutes later, Marlon asked Rabon to leave the office and
19 “give me and [Gahyne] a few minutes, please.”
20 319. Rabon complied with Marlon’s request, leaving, and closing the door.
21 320. Seeland had to have known that Marlon had requested Rabon to leave him alone
22 with Plaintiff.
23 321. Seeland permitted Marlon to be alone with Plaintiff, despite her plea, less than
24 a half hour earlier that she is not left alone with Marlon because he would use the opportunity
25 to further brutalize her.
26 322. Plaintiff was terrified that Marlon would again engage in his violent sexual
27 tendencies, but also that this time, it would be even worse because Seeland would obviously
28 facilitate Marlon’s desires.
Page 28 of 40
 1 323. Once alone with her, Marlon threatened Plaintiff stating that if she referred this
2 matter to her attorney, he would sue her and her (at that time) legal counsel (Phil Trenchak) for
3 coercion or conspiracy.
4 324. Later, Plaintiff discovered that the threat to personally involve her legal counsel
5 was meant in earnest when she discovered that Marlon had retained an attorney as part of his
6 legal team, who, on behalf of a different client, had recently sued Trenchak and others and lost.
7 325. Despite the frivolous nature of the threat, nonetheless, Plaintiff’s previous
8 counsel withdrew upon learning that Marlon intended to involve him personally, and his firm,
9 in a spurious lawsuit designed to chill Plaintiff’s right to petition.
10 326. Then Marlon offered Plaintiff $1,000 and the ability to work remotely from
11 Florida, to withdraw her claims
12 327. On or about June 22, 2021, Marlon responded to Seeland regarding the EEOC
13 filing stating that “{Gahyne} showed me some of those pictures but explained that they were
14 from Phil Trenchak.”
15 328. In the same response to Seeland, Marlon stated “I am shocked at these false
16 allegations.”
17 329. At the very least, Marlon’s response to Seeland was misleading, as Marlon
18 understood he had personally taken a number of photographs of Plaintiff’s bruised rear end in
19 various of the Crossroads offices and Vegas Stronger offices.
20 330. Indeed, at least one photograph of Plaintiff’s bruised rear end shows (a) the
21 distinctive green carpeting of the Crossroads office, and (b) a chew toy favored by Marlon’s
22 dog.
23 331. A separate photograph shows the same chew toy and the dog on the distinctive
24 green carpet thereby authenticating that the photograph was taken at the Crossroads office.
25 332. Further, Marlon’s attempt to claim that Plaintiff’s counsel took the photographs
26 is absurd, as none of Plaintiff’s counsel had never been in any of the offices.
27 333. Thereafter, Seeland verbally approved that Plaintiff could take a leave of
28 absence and use her PTO to cover her paycheck if she gives the Company a doctor’s note.
Page 29 of 40
 1 THE CORPORATIONS BEGIN RETALIATING AGAINST PLAINTIFF FOR
2 REPORTING MARLON’S SEXUAL ASSAULT
3 334. After she complained to Seeland, and two days after she filed a Charge of
4 Discrimination with the EEOC for sexual harassment, Plaintiff began receiving urgent emails
5 requesting that she fill out information for a “pre-employment” background check, which was
6 necessary before she could begin her employment.
7 335. This was the first time a background check had ever been mentioned to Plaintiff
8 since she began working with Marlon in April 2021.
9 336. Further, Plaintiff was told that she needed to sign a form confirming that she had
10 attended an orientation, which she had never attended and confirming receipt of an employee
11 handbook, which she had never received before receiving the email containing the same.
12 337. Thereafter, Plaintiff was deliberately given conflicting and confusing
13 instructions as to what documentation she needed to provide for her requested leave, ensuring
14 Plaintiff stayed concerned for her job.
15 338. In particular, the Company/Companies refused to accept the work excuse from
16 the hospital, stating that a signed note was necessary to verify her leave, despite Plaintiff (and,
17 upon information and belief, the hospital) verifying that a signed note was not possible to obtain
18 from the Emergency Department.
19 339. Thereafter, Plaintiff provided an excuse from her primary care physician, which
20 was duly signed.
21 340. Seeland complained that her doctors note had “really small print” and asked for
22 another copy, which Plaintiff provided.
23 341. However, despite this, the note which was duly signed as required, was
24 nonetheless rejected by Seeland.
25 342. As a result, Plaintiff was not allowed to use her PTO, resulting in financial
26 difficulties.
27 343. Thereafter, without warning, and despite Plaintiff being on leave, Crossroads
28 withdrew approximately $1600 from Plaintiff’s checking account.
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 1 344. To date, no coherent explanation has been given as to why the monies were
2 withdrawn.
3 345. Further, no explanation has been posited why the money was re-deposited
4 shortly thereafter.
5 346. In a further act of retaliation, Plaintiff’s health insurance was cancelled without
6 warning or notice, indicating that Plaintiff had been terminated.
7 347. However, no confirmation of termination was provided to Plaintiff.
8 348. Further, Defendants failed to offer Plaintiff COBRA coverage.
9 349. The lack of health insurance has been devastating to Plaintiff who not only
10 suffered through these brutal and vicious attacks, but has since been diagnosed with early onset
11 dementia, likely arising out of the trauma she suffered at the hands of the Defendants.
12 350. Further, the lack of health insurance has significantly hindered Plaintiff’s ability
13 to seek the mental health support she desperately needs after surviving this ordeal.
14 351. Upon information and belief, after Plaintiff complained of Marlon’s behavior,
15 Marlon began to have her followed, ensuring she remained constantly in a state of fear and
16 anxiety.
17 352. When confronted, it was confirmed that part of Marlon’s strategy was to have
18 Plaintiff followed.
19 353. Further, Marlon and/or Marlon’s ex-girlfriend Brittany Andrews8, believed to
20 be a professional Dominatrix and Hall of Fame Porn Star, contacted Plaintiff’s ex-fiancé (and
21 possibly others), and inquired into Plaintiff’s personal life and asked specifically about “bad
22 behavior” Plaintiff had engaged in that would “help [her] good friend, Dave.”
23 354. Brittany Andrews, Marlon’s ex-girlfriend accused Plaintiff of “extortion” and
24 “blackmail.”
25 355. Plaintiff’s ex-fiancé, with whom Plaintiff has always maintained a cordial
26 platonic relationship after the romantic portion of their relationship ended, refused to provide
27
28 8
Brittany Andrews may be a stage name.

Page 31 of 40
 1 any information on the basis that there was no information to provide.
2 356. Marlon’s interference with Plaintiff’s personal life is particularly problematic
3 because Andrews made the accusations to another member of Plaintiff’s Alcoholics
4 Anonymous Group, to which Andrews also belonged.
5 357. Marlon knew, or should have known, that causing unnecessary and untoward
6 “drama” in Plaintiff’s AA meeting would have the effect of alienating Plaintiff from her support
7 structure, thereby increasing the likelihood that Plaintiff would relapse.
8 358. In fact, as a direct result of Marlon’s actions and threats, Plaintiff did briefly
9 relapse, but has since recovered and continues to struggle to reestablish and maintain her
10 sobriety as outlined above, despite Marlon’s continued interference.
11 359. Plaintiff is a recovering alcoholic and drug addict.
12 360. Until October 2021, Plaintiff had been clean and sober for nearly 22 months.
13 361. Unfortunately, due to the strain of this matter, including Marlon and upon
14 information and belief, others acting on Marlon’s behalf, Plaintiff had a brief relapse in October
15 2021.
16 362. To resolve this matter, and prior to filing this Complaint, Plaintiff, Marlon, and
17 their respective legal teams met in Las Vegas.
18 363. On the way into the meeting, Marlon followed Plaintiff, mocking her as he spoke
19 on the phone to someone stating “yeah, I’m right behind {Gahyne} now.”
20 364. He then hung up and stated to Plaintiff “Hey we can ride up in the elevator
21 together” as he followed her to the building’s elevator which was just a few feet away.
22 365. Given the circumstances, Plaintiff interpreted Marlon’s actions as a threat.
23 366. When the elevator reached the floor, a member of Plaintiff’s party stepped out
24 of the elevator and insisted that Marlon not enter the elevator.
25 367. Horrified, shaken, and realizing, yet again, that Marlon had no conscience or
26 issues harassing her further, Plaintiff began drinking shortly after the meeting.
27 368. Marlon’s threats at what was supposed to be a meeting to resolve the matter,
28 only exacerbated Plaintiff’s trauma and distress and caused her relapse.
Page 32 of 40
 1 369. Thereafter, Plaintiff realized that she needed assistance and reached out through
2 her support network and is once again, clean, and sober.
3 FIRST CAUSE OF ACTION
4 (Sexual Assault/Battery)
5 (All Defendants)
6 370. Plaintiff incorporates all the allegations in the preceding paragraphs as though
7 fully set forth herein.
8 371. During her employment with Marlon and the various corporate defendants,
9 Plaintiff was subjected to an unwelcome vicious, extreme, outrageous, pervasive, and
10 unrelenting campaign of physical violence and mental torture by Marlon as detailed above.
11 372. Marlon willfully inflicted unlawful force and violence upon Plaintiff.
12 373. Such conduct included, but not limited to, acts which were sexual in nature.
13 374. Marlon intended the conduct to be harmful and offensive.
14 375. As a result of Marlon’s conduct, Plaintiff was physically, mentally, and
15 emotionally harmed.
16 376. The Corporate Defendants, as the employer(s) of Marlon, are jointly and
17 severally liable for Marlon’s actions under the doctrine of Respondeat Superior.
18 377. As a result of these illegal actions, Defendants must pay damages in an amount
19 more than fifteen thousand dollars ($15,000.00).
20 378. Because Defendants are guilty of oppression, fraud, or malice, express or
21 implied, Defendants must pay Plaintiff an additional amount for the sake of example and by
22 way of punishment.
23 379. Plaintiff has had to obtain the services of an attorney to protect her rights and
24 secure compensation for the damages incurred because of these violations, as such she is
25 entitled to recover reasonable attorney’s fees and costs of suit.
26 ///
27 ///
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 1 SECOND CAUSE OF ACTION
2 (Assault)
3 (All Defendants)
4 380. Plaintiff incorporates all the allegations in the preceding paragraphs as though
5 fully set forth herein.
6 381. While employed with Marlon and the various corporate defendants, Marlon
7 subjected Plaintiff to an unwelcome vicious, extreme, outrageous, pervasive, and unrelenting
8 campaign of physical violence and mental torture as outlined above.
9 382. Such campaign included Marlon’s conveying various threats of bodily harm to
10 Plaintiff which included but were not limited to threats to choke her to unconscious, kick her
11 while unconscious, have her gang raped, and near constant threats of physical violence such as
12 paddling, whipping and/or use of a riding crop.
13 383. Marlon carried out at least some of these threats, and thus, Plaintiff was aware
14 that Marlon had the ability to carry out the threats.
15 384. Marlon’s history of violence against Plaintiff put her in a reasonable
16 apprehension of physical harm and on more than one occasion, such physical harm was
17 imminent.
18 385. As a result of Marlon’s conduct, Plaintiff was physically, mentally, and
19 emotionally harmed.
20 386. The Corporate Defendants, as the employer(s) of Marlon, are jointly and
21 severally liable for Marlon’s actions under the doctrine of Respondeat Superior.
22 387. As a result of these illegal actions, Defendants must pay damages in an amount
23 in excess of fifteen thousand dollars ($15,000.00).
24 388. Because Defendants are guilty of oppression, fraud, or malice, express or
25 implied, Defendants must pay Plaintiff an additional amount for the sake of example and by
26 way of punishment.
27 389. Plaintiff has had to obtain the services of an attorney to protect her rights and
28 secure compensation for the damages incurred because of these violations, as such she is
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 1 entitled to recover reasonable attorney’s fees and costs of suit.
2 THIRD CAUSE OF ACTION
3 (False Imprisonment)
4 (All Defendants)
5 390. Plaintiff incorporates all the allegations in the preceding paragraphs as though
6 fully set forth herein.
7 391. On one or more occasion during Plaintiff’s employment, Marlon intended to and
8 did physically trap, restrain or otherwise confine Plaintiff without legal justification, against her
9 will and with her full knowledge.
10 392. Marlon’s actions in blocking the door to the group therapy room while he raped
11 her and his various actions in physically restraining plaintiff while she struggled were done with
12 the intent to deprive Plaintiff of her liberty and done without legal justification or consent.
13 393. As a result of Marlon’s conduct, Plaintiff was physically, mentally, and
14 emotionally harmed.
15 394. The Corporate Defendants, as the employer(s) of Marlon are jointly and
16 severally liable for Marlon’s actions under the doctrine of Respondeat Superior.
17 395. As a result of these illegal actions, Defendants must pay damages in an amount
18 in excess of fifteen thousand dollars ($15,000.00).
19 396. Because Defendants are guilty of oppression, fraud, or malice, express or
20 implied, Defendants must pay Plaintiff an additional amount for the sake of example and by
21 way of punishment.
22 397. Plaintiff has had to obtain the services of an attorney to protect her rights and
23 secure compensation for the damages incurred because of these violations, as such she is
24 entitled to recover reasonable attorney’s fees and costs of suit.
25 FOURTH CAUSE OF ACTION
26 (Negligence Per Se)
27 (All Defendants)
28 398. Plaintiff incorporates all the allegations in the preceding paragraphs as though
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 1 fully set forth herein.
2 399. Marlon’s actions in inflicting mental torture, physical harm and sexual assault
3 on Plaintiff are a violation of a variety of Nevada statutes designed to ensure the safety and
4 bodily integrity of Nevada citizens and residents.
5 400. Such statutes include, but are not necessarily limited to:
6 a. NRS 200.275 (Bodily Injury)
7 b. NRS 200.364 et. seq. (Sexual Assault and Seduction)
8 c. NRS 200.400 (Battery with Intent to Commit a Crime)
9 d. NRS 200.460 (False Imprisonment)
10 e. NRS 200.471 et. seq. (Assault and Battery)
11 f. NRS 200.571 et. seq. (Harassment and Stalking)
12 401. The type of harm caused by Marlon is the type of harm these various statutes are
13 designed to prevent.
14 402. As a citizen and resident of Nevada, Plaintiff is among the class of persons meant
15 to be protected by these statutes.
16 403. As a result of Marlon’s conduct, Plaintiff was physically, mentally, and
17 emotionally harmed.
18 404. The Corporate Defendants, as the employer(s) of Marlon are jointly and
19 severally liable for Marlon’s actions under the doctrine of Respondeat Superior.
20 405. As a result of his illegal actions, Defendant Marlon must pay damages in an
21 amount in excess of fifteen thousand dollars ($15,000.00).
22 406. Because Defendant is guilty of oppression, fraud, or malice, express or implied,
23 Defendant must pay Plaintiff an additional amount for the sake of example and by way of
24 punishment.
25 407. Plaintiff has had to obtain the services of an attorney to protect her rights and
26 secure compensation for the damages incurred because of these violations, as such she is
27 entitled to recover reasonable attorney’s fees and costs of suit.
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 1 FIFTH CAUSE OF ACTION
2 (Intentional/Negligent Infliction of Emotional Distress)
3 (All Defendants)
4 408. Plaintiff incorporates all the allegations in the preceding paragraphs as though
5 fully set forth herein.
6 409. Defendants’ conduct toward Plaintiff was extreme and outrageous and caused
7 significant emotional harm, headaches, sleeplessness, and various physical and mental distress.
8 410. Defendants’ conduct was extreme, outrageous, and undertaken with either intent
9 or, reckless disregard for causing Plaintiff emotional distress.
10 411. Defendants had a duty to refrain from engaging in the hostile and retaliatory acts
11 as described above. Such behavior included, but was not limited to:
12 a. Targeting Plaintiff for sexual servitude, knowing that she was emotionally
13 vulnerable due to her recovery and her financial state
14 b. Continuing to permit Marlon to harass and threaten Plaintiff even after Plaintiff
15 complained of Marlon’s behavior
16 c. Continuing to permit Marlon and possibly others to stalk, harass, target, and
17 follow Plaintiff, thereby ensuring her constant fear for her safety
18 d. Marlon’s continued stalking, harassment, and threats to Plaintiff.
19 e. Accusing Plaintiff of engaging in criminal activity and
20 f. interfering with Plaintiff’s support system, putting plaintiff at significantly
21 increased risk of relapse.
22 412. Defendants breached that duty.
23 413. Defendants intentional or negligent conduct was the legal, actual, proximate
24 cause of Plaintiff’s damages by engaging in the conduct described herein.
25 414. The Corporate Defendants, as the employer(s) of Marlon are jointly and
26 severally liable for Marlon’s actions under the doctrine of Respondeat Superior.
27 415. As a result of these illegal actions, Defendants must pay damages in an amount
28 in excess of fifteen thousand dollars ($15,000.00).
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 1 416. Because Defendants are guilty of oppression, fraud, or malice, express or
2 implied, Defendants must pay Plaintiff an additional amount for the sake of example and by
3 way of punishment.
4 417. Plaintiff has had to obtain the services of an attorney to protect her rights and
5 secure compensation for the damages incurred because of these violations she is entitled to
6 recover reasonable attorney’s fees and costs of suit.
7 SIXTH CAUSE OF ACTION
8 (Negligent Supervision/Training/Hiring/Retention)
9 (Corporate Defendants)
10 418. Plaintiff incorporates all the allegations in the preceding paragraphs as though
11 fully set forth herein.
12 419. Defendants studiously ignored multiple complaints regarding Marlon’s sexual
13 proclivities and tendency to target female employees, particularly those who had previously
14 been in detox and/or rehab and or recovery with companies owned, controlled, or with which
15 Marlon was otherwise involved, including at least one previous employee of Vegas
16 Stronger/Crossroads.
17 420. Defendants knew or should have known of Marlon’s proclivities for improper,
18 unreasonable, outrageous, harassing, and retaliatory actions such that an exercise of reasonable
19 care would have stopped and or prevented such conduct.
20 421. Defendants’ failure to supervise its employees and address this conduct in an
21 appropriate way caused injury to Plaintiff.
22 422. Crossroads and Vegas Stronger permitted Marlon to continually and repeatedly
23 subject Plaintiff to violence and sexual assault.
24 423. Plaintiff voiced her complaints and concerns to John Seeland, who acted as the
25 Human Resources person and specifically requested that she not be required to be alone with
26 Marlon.
27 424. Approximately twenty minutes later, Seeland deferred to Marlon’s request to be
28 alone with Plaintiff, despite her stated objections shortly prior and his assurances that such
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 1 would not occur.
2 425. After Plaintiff voiced her complaints to the Human Resources Department,
3 Plaintiff was subject to threats, hostility, and retaliation.
4 426. Thereby, the Corporate Defendants affirmed, ratified, and acquiesced in the
5 actions undertaken by Marlon.
6 427. Defendants’ intentional and/or negligent conduct was the legal, actual,
7 proximate cause of Plaintiff’s damages.
8 428. As a result of these illegal actions, Defendants must pay damages in an amount
9 in excess of fifteen thousand dollars ($15,000.00).
10 429. Because Defendants are guilty of oppression, fraud, or malice, express or
11 implied, Defendants must pay Plaintiff an additional amount for the sake of example and by
12 way of punishment.
13 430. Plaintiff has had to obtain the services of an attorney to protect her rights and
14 secure compensation for the damages incurred because of these violations and therefore, she is
15 entitled to recover reasonable attorney’s fees against Defendants.
16 ///
17
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19
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21
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 1 WHEREFORE, Plaintiff prays this Court for:
2 a. An award of damages sufficient to fully compensate her (including tax
3 consequences) for all economic losses of any kind, and otherwise make her
4 whole in accordance with the law.
5 b. General damages.
6 c. Special damages.
7 d. Emotional damages.
8 e. An award of compensatory and punitive damages to be determined at trial.
9 f. Liquidated damages.
10 g. Pre- and Post-Judgment Interest.
11 h. An award of reasonable attorney’s fees and costs.
12 i. Any other relief the court deems just and proper.
13 DATED: November 15, 2021
14 HKM EMPLOYMENT ATTORNEYS, LLP
15
By: /s/ Jenny L. Foley
16 JENNY L. FOLEY
Nevada Bar No. 9017
17 E-mail: jfoley@hkm.com
1785 East Sahara, Suite 300
18 Las Vegas, Nevada 89104
Tel: (702) 805-8340
19 Fax: (702) 805-8340
20 Attorney for Plaintiff

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