79C01-1804-CT-000055 Filed: 4/10/2018 10:26 AB Cie Tippecanoe Circuit Court Tippecanoe County, nan: STATE OF INDIANA ) IN THE TIPPECANOE COUNTY CIRCUIT COURT ) 88: COUNTY OF TIPPECANOE ) CAUSE NO. ALYSSA CHAMBERS, ) ) Plaintiff, ) ) Vv. ) JURY TRIAL REQUESTED ) ISAAC HAAS, ) and ) PURDUE UNIVERSITY, ) ) Defendants. ) COMPLAINT FOR PERSONAL INJURIES Comes now Plaintiff, Alyssa Chambers (hereinafter “Alyssa”), individually and by einafter “Haas”) aaa EBS. :e:cinatc MAM and Purdue University (hereinafter “Purdue”), says: counsel, and for her Complaint against Defendants, Isaac Haas (li At all times material hereto, Alyssa was a student at Purdue University in West Lafayette, Tippecanoe County, Indiana, At all times material hereto, Isaac Haas was a student at Purdue University in West Lafayette, Tippecanoe County, Indiana. Atall times material hereto ¥ijGQQNEAINGD was a non-resident of the State of Indiana engaged in interstate electronic communications with residents of and in West Lafayette, ‘Tippecanoe County, Indiana. At all times material hereto, Purdue was a public university providing education and other services, operating in Tippecanoe County, Indiana, including athletic coaching, healthcare services and consultation for and to Haas,5. On or about May 15, 2017, Alyssa and Haas entered into a brief sexual relationship, Prior to beginning the sexual relationship, Haas explicitly assured Alyssa he had been tested for sexually transmitted diseases, had previously contracted chlamydia, received treatment and was currently without a sexually transmitted disease or condition. 7. Shortly following the initiation of the sexual relationship, Alyssa discovered she had been infected with sexually transmitted diseases; i.e., chlamydia and/or herpes simplex virus. When Alyssa became aware of a potential sexually transmitted disease she informed Haas of that possibility, at which time he acknowledged his experience with chlamydia, stating “Chlamydia is a such a shit to get rid of. In one day the whole frickin deal can fuck you up and change”. (See Exhibit A attached hereto). 2 Subsequently, Haas further admitted in electronic correspondence that because he knew he had incurred a prior sexually transmitted disease he should have taken precautions to prevent spreading such disease to his other sexual partners, stating: HAAS: —_I’'mso sorry. Goddamn it I feel like such an asshole. I should’ve worn one until I knew for sure, and even then still wom one. (Emphasis added). Fuck. . . I’m so sorry ALYSSA: I wouldn’t beat yourself up about it too much, HAAS: Well I mean wif it could EASILY been prevented [just had to frickin grow up 10. Haas then also shifted blame to a Purdue entity, "PUSH", for misinforming, him he was "clean": HAAS: Well if anything hold it against push cause these mfers told me Iwas clean(See Exhibit C attached hereto; emphasis added). AL, Subsequently, Alyssa received electronic correspondence from an aaa QGPBED (possibly an alias for Defendant fgggBP). informing Alyssa that Haas had infected a number of other individuals prior to Alyssa, thus confirming Haas' knowledge of his own sexually transmitted disease condition. (See Exhibit D attached hereto). 12. _ In addition, Alyssa was then contacted ye who had a previous romantic and/or sexual relationship with Haas, wherein {JJM recounted her knowledge of Haas and his sexually transmitted disease history: QM, '.-. says he never got formally tested. that the doctor just believed him when he said he was showing symptoms and gave him medicine because he's technically not been "diagnosed" with herpes either He is full of shit. I have texts where he said he was formally tested before we had sex. And I have texts where he talked about having a qtip up his penis when they were "testing" him. QAI i vied 10 get him with a lawyer because i didn't find out about herpes until i was 6 months into the relationship. our families went at it, and he's never formally been tested for herpes so i couldn't do anything. ALYSSA: he has never been tested. perks of being an athlete, the doctor just gives you meds. he told you he was tested so you would sleep with him because he can say "he didn't know" (See Exhibit E attached hereto; emphasis added). L ‘Thereafter, Haas discussed with @QQQMQ@MGR his potential liability for the sexually transmitted disease infection incurred by Alyssa, and how to cover up and/or dispute Alyssa's claims:HAAS: HAAS: HAAS: EE HAAS: HAAS: Thave to pay for my actions. Fither in money, or a charge. you are right, maybe this will finally be an eye opener that you can't just take the easy way out of everything 10,000 or 6 months to 50 years in jail depending on extremity of disease I'm literally freaking out You know I have to deny everything. Deny knowing. All that (emphasis added) why In order to lessen the sentence Please keep this between us Try to talk her down if anything she has her mind pretty set ‘Why not ican't persuade her What were you saying? i can't talk her down? what am i suppose to say. oh please don't do it?? Just be like please don't. He's learned his lesson, He will do what it takes to make it right. But putting him in jail isn't going to do anything but ruin other peoples lives and put HER name in public conversation of being infected with herpes Because all criminal files are publi information. And if the media gets ahold of that, then not only will it blow up, but her name will be all over it too. you can't do anything to make it right Isaac. ‘That is something she will ive with for the rest of her life?HAAS: Yes I know. And I feel horrible about it. But she wants to not only ruin my life, but others around me, and put her name out there like that? (See Exhibit F attached hereto). 14. On September 7, 2017, counsel for Alyssa served upon Haas a "Notice of Claim and Demand For Preservation of Electronic Data, Documents, and Materials relevant to proving the cause and extent of Ms. Alyssa Chambers! injuries incurred in the Spring/Summer of 2017." (See Exhibit G attached hereto). 15, After Haas was served with the aforementioned notice/spoliation letter, gM sent electronic correspondence to Alyssa stating (IMM had been advised "via one of the coaches" that Haas had received such documents, and that purportedly "a lot of the stuff you heard from me wasn't true because I was mad at Isaac and I was trying to intentionally trying to fuck with you. Just letting you know", (See Exhibit H attached hereto; emphasis added). 16. The above-referenced statement by SUMP constitutes either an admission of an intentional infliction of emotional harm, or evidence of a conspiracy among Haas QQ and Purdue coaches to cover up Haas’ knowledge and wrongful conduct, just as he had previously indicated he would attempt to do. On November 1, 2017, counsel for Alyssa sent a Notice Of Tort Claim to the appropriate government officials concerning those matters set forth in the preceding paragraphs of this Complaint. (See Exhibit I attached hereto). The contents of said Notice Of Tort Claim are incorporated herewith as if fully set forth verbatim in this Complaint, 18, The acts and conduct of Defendants, individually and collectively, constitute battery, intentional infliction of physical and emotional harm, negligent infliction of physical and emotional harm, fraud, conspiracy to commit fraud and negligence in general.WHEREFORE, for all of those reasons set forth above, Plaintiff, Alyssa Chambers, prays for judgment against Defendants, Isaac Haas, QQRCRGGEED and Purdue University, in an amount which will fully, fairly and adequately compensate said Plaintiff for all injuries, damages, costs and expenses recoverable under Indiana law, and for all other just and proper relief in the premises. JURY TRIAL REQUEST Comes now Plaintiff, Alyssa Chambers, by counsel, and requ ts a trial by jury in the above-captioned cause of action. Thereby swear and affirm that the allegations set forth in the Complaint herein are true and accurate to the best of my knowledge. Alyssa’ hatesRespectfully submitted, s/Michael E, Simmons Michael E, Simmons HUME SMITH GEDDES GREEN & SIMMONS, LLP Attorney No. 136-49 54 Monument Circle, 4th Floor Indianapolis, Indiana 46204 Telephone: (317) 632-4402 Facsimile: (317) 632-5595, msimmons@ln Ann Marie Waldron WALDRON LAW Attorney No. 18833-49A. 333 East Ohio Street, Suite 200 Indianapolis, Indiana 46204 Office: (317) 686-1900, ext. 223 Cell: (317) 796-0664 Facsimile: (317) 686-5760 amwaldron@amwaldronlaw.com Attorneys for Plaintiff