FACTUAL ALLEGATIONS

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1.

The facts supporting the foregoing complaint occurred between September 21,

2015 through September 23, 2015. The location of the incident is at the real property located at
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2571 Wallingford Drive, Beverly Hills, California 90210 (hereinafter "Property").

2.

Plaintiffs were hired by Defendant AL SAUD to work out of his Property and

provide general housekeeping and food service duties for himself and his entourage during his

visit to California. Plaintiffs were retained as employees for Defendant AL SAUD via a third

party service.

3.

AL SAUD is from Saudi Arabia and a member of the Saudi Royal Family.

4.

AL SAUD employed at least three people during this trip.

5.

Plaintiffs performed their duties in a competent and satisfactory manner.

6.

AL SAUD was accompanied with his own security guards and butlers from Saudi

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Arabia and other friends. All of them stayed at the Property at all relevant times herein. AL
SAUD and his entourage, specifically AL SAUD, his butlers, and personal assistants, supervised

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and controlled Plaintiffs day to day duties while employed by AL SAUD.

7.

On or about September 21, 2015, AL SAUD arranged for a party to take place at

the Property. AL SAUD arranged for multiple escorts to attend the party at the Property. AL

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SAUD became increasingly intoxicated throughout the course of the evening and was engaging

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in illicit drug abuse. All Plaintiffs were present at various points throughout the evening.

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8.

Plaintiffs are informed and believe and thereon allege that AL SAUD was using

cocaine throughout the course of their employment. They witnessed white residue around his
nose and he often signaled to the escorts to the other room while pointing to his nose. Plaintiffs
noticed that his eyes were abnormally dilated while working for him.
9.

The evening of September 22, 2015, AL SAUD had another party at the Property.

AL SAUD continued to engage in heavy drinking, cocaine use and more escorts came to the
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residence.
10.

That evening, no less than 10 times, AL SAUD violently grabbed and pulled

JANE DOE 1's hand. He made statements to her to the effect of, "I like you" and he insisted that

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JANE DOE 1 stay near him at all times. However, JANE DOE 1 was told that AL SAUD is

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paranoid and that she should never stand in one place and must always be moving around. That

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evening AL SAUD also threatened JANE DOE 1 and said to her, "tomorrow I will have a party
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with you and you will do everything I want, otherwise I will kill you." JANE DOE 1, afraid for
life, freed herself from AL SAUD's grip and quickly went into another room.
11.

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At one point that day, Plaintiffs were in the living room area. AL SAUD walked

into the room and began unzipping his trousers and shouted, I want to pee pee!" while
attempting to remove his penis from his trousers. AL SAUD was preparing to urinate on or
around the Plaintiffs but was stopped by an assistant of his and was taken outside. The Plaintiffs,
concerned for their safety, attempted to hide from AL SAUD in the dining room next door.
12.

Approximately 10 minutes later, AL SAUD followed JANE DOE 1, JANE DOE

2, and JANE DOE 3 in the dining room area. AL SAUD jumped on top of JANE DOE 2 while

she was seated and started rubbing his body against her body in a sexual and aggressive manner.

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JANE DOE 2 pleaded with AL SAUD to stop. AL SAUD stood up and yelled something to the
effect, "I am a prince and I do what I want! You are nobody!" Instead, AL SAUD jumped on
JANE DOE 2 again and continued to aggressively rub his body against hers and JANE DOE 2
again pleaded with him to stop, saying Im a woman. AL SAUD stood up and, once again,
yelled, youre not a woman! Youre nobody! Im a prince and Ill do what I want and nobody
will do anything to me!
13.

Plaintiffs, afraid for their lives, ran to the balcony to escape AL SAUD. While

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on the balcony, one of AL SAUD'S assistants yelled at the Plaintiffs to get back to work. The

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assistant (name unknown) informed Plaintiffs that AL SAUD needed constant service and that

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they were never allowed to take breaks or leave AL SAUD unattended. He grabbed JANE DOE

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2's hand and tried to force her inside to continue working.

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14.

Plaintiffs, in tears, informed the assistant that they were afraid for their lives

because they witnessed AL SAUD physically attack his assistants and butlers, pulled their ears,
threw objects at them, punched them in the face, and were afraid for their own physical safety.
The Plaintiffs attempted to reach AL SAUD's security to protect them but they were far from the

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Property and did not timely return to keep the Plaintiffs safe. The assistant informed the
Plaintiffs that they had no choice but to provide constant service.
15.

Consequently, JANE DOE 2 approached AL SAUD to continue pouring his

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alcoholic beverages, and AL SAUD yanked JANE DOE 2s arm and pulled her closer to him and

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kicked her violently above the knee while maintaining his grip on her arm. This violent attack

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left AL SAUD's nail marks on her wrist and bruises on her thigh. AL SAUD yelled at JANE
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DOE 2 and instructed her to call over JANE DOE 1, presumably so that he could inflict pain on
her as well. JANE DOE 2 refused and ran out of the room.
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Once again, Plaintiffs ran to the second floor balcony for safety. Plaintiffs had

nowhere else to hide; JANE DOE 3 tried to leave through the front door and the garage door
earlier in the evening, but both were locked from the inside by AL SAUD and/or his staff.
Trapped on the balcony, Plaintiffs began to cry, they were sure \ that AL SAUD would kill them.

Plaintiffs thought about jumping onto the concrete below, knowing that they would break their

limbs and hoping to survive. JANE DOE 1 and JANE DOE 2 thought about their children and

that they would not have a chance to say goodbye.

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going to go upstairs. Ill be up there in 2 minutes and youll do whatever I want. If not, then Ill
kill you. JANE DOE 3 did not comply as she believed that being alone with AL SAUD would
surely result in her rape or death.
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At some point, AL SAUD instructed JANE DOE 3 to do the following: youre

Plaintiffs again, in tears and afraid for their physical safety, ran into another room

to escape AL SAUD's verbal and physical attacks. AL SAUD was becoming increasingly
agitated and aggressive. He began to make scream\ and make animal like sounds. At one point,
there was a loud bang heard by the Plaintiffs. This was followed by one of AL SAUD's

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assistants screaming at the girls to run as he feared for the Plaintiffs' safety. The Plaintiffs ran

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after AL SAUDs assistant who opened the Property doors in order for them to escape from the

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Property. They left their purses and other personal property at the premises.

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19.

Plaintiffs, afraid for their lives, did not want to return to their next working shift.

However, they were forced to return, in order to retrieve their personal belongings. Plaintiffs
were assured that AL SAUD had slept it off and would not bother them anymore; when they
informed AL SAUDs agent that they were fearful for their lives, they were told that they would
not get paid their wages for the last two days unless they returned to work.

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20.

When Plaintiffs arrived for their next shift, they were immediately yelled at by

AL SAUD's assistants. Again, they were told that they were not allowed to leave AL SAUD
unattended and without waiting services at any point. They were told that AL SAUD required
uninterrupted 24 hours service.
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AL SAUD immediately started yelling at Plaintiffs and asked them why they were

gone for so long. AL SAUD kept yelling that he was not going to pay the Plaintiffs "one cent" of
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their lawful wages because they left the Property for approximately five hours. It was clear that
AL SAUD had not slept for days.
22.

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Later that day on September 23, 2015, Plaintiffs were shocked to witness AL

SAUD being masturbated by another man. Plaintiffs witnessed a man on his knees (name
unknown) kneeling in front of AL SAUD. AL SAUD had his penis exposed and the unidentified
man was stroking AL SAUD's penis. AL SAUD noticed the Plaintiffs attempting to leave the

room and screamed, you must watch this! JANE DOE 1 and JANE DOE 3 were forced by

AL SAUD to watch a man stroke AL SAUD's penis.

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23.

Later that day, JANE DOE 1 witnessed another man on his hands and knees

passing gas in AL SAUD's face, at AL SAUD's instruction. Again, Al SAUD commanded

JANE DOE 1 to watch this take place.
24.

At some point on September 23, 2015, AL SAUD told JANE DOE 1 that he

caught his girlfriend (hereinafter "Girlfriend") having sex with another man in the bathroom stall
while they were at a night club that prior evening.

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25.

AL SAUD also told JANE DOE 3 that something to the effect to of "he didn't

need his girlfriend anymore." JANE DOE 3 heard AL SAUD aggressively yelling at Girlfriend
and heard him make statements to the effect of "after what you did, I dont need you! Get out!"
26.

Later, AL SAUD grabbed JANE DOE 1's arm and he said something to the effect

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of "I will pay you but you have to lick my entire body. If you make me feel good, you'll feel

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good too." JANE DOE 1 pulled away and within a few seconds AL SAUD instructed JANE

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DOE 1 to gather everyone by the pool (housekeepers and security guards) and to get naked

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because he wanted to see everyone's "naked pussy."

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At this point, AL SAUD was intoxicated, aggressive, abusive, and shouting. His

eyes were filled with rage. Several times throughout out the course of Plaintiffs employment, he
threatened to kill the Plaintiffs if they did not do exactly as he commanded. Plaintiffs were afraid

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for their lives.

28.

Plaintiffs ran outside and the police were called to the scene. While waiting

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outside, Plaintiffs saw Girlfriend and another female with bruises and blood on their face and

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body. They were shaking and crying. While JANE DOE 2 was being questioned by a LAPD

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officer, AL SAUDs assistant attempted to video conference with another individual on his

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Iphone, presumably to show JANE DOE 2s identity to ensure her silence or inflict physical
harm upon her.
29.

AL-SAUD, delirious and enraged, was led out of the Property by police,

screaming, no news!

30.

Plaintiffs are in fear for their lives and believe that AL SAUD will have them

31.

Plaintiffs have still not been paid for services performed for AL SAUD.

32.

Plaintiffs reserve the right to amend this Complaint at a future date to include the

killed.

facts supporting the foregoing causes of action.

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DATED:

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By:_____________________________
FRISH LAW GROUP, APLC
Vadim F. Frish
Stanislav Pekler

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BEROKIM & DUEL P.C.

Jasmine Duel
Kousha Berokim

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Attorneys for Plaintiffs Jane Doe 1, Jane

Doe 2, and Jane Doe 3

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