1. Plaintiff Jane Doe brings this action for damages resulting from sex trafficking. Jane Doe was trafficked to the United States and forced to work as a prostitute, mostly in Fairfax County, Virginia. At least some of the defendants, at the time officers within the Fairfax County Police Department (“FCPD”), provided security to the trafficking ring that ensnared Jane Doe, secured sexual services from trafficked women, and may also have extorted money from the ring’s leadership. During and after Jane Doe’s trafficking, high ranking officers within the department conspired to cover up aspects of sex trafficking in Fairfax, and the complicity of county police officers in the work of the trafficking ring, thereby becoming themselves complicit in its work to the point of permitting two knowingly highly compromised officers to retire quietly on pensions. The officers complicit in this coverup included the then chief of police, who was the policy-making individual for Fairfax County with regard to law enforcement, including the county’s approach to sex trafficking occurring within its borders. The result was the creation of a county custom, practice or usage of tolerating sex trafficking and suppressing investigation thereof over a period of time.
Doe v. Fairfax Police Officer 1 by TerryMaynard on ScribdThe full text of the amended complaint is available here.