Vambo Posted May 24, 2023 Report Share Posted May 24, 2023 https://thedawgspodcast.com/wp-content/uploads/2023/04/deshaun-watson-original-answer.pdf CAUSE NO. 2021-15324ASHLEY SOLIS, a/ka/ Jane Doe § IN THE DISTRICT COURT OF§Plaintiff, §§VS. § HARRIS COUNTY, T E X A S§DESHAUN WATSON, §§Defendant. § 113 th JUDICIAL DISTRICTDEFENDANT DESHAUN WATSON’S ORIGINAL ANSWERSince March 16, 2021, when the first of twenty-two lawsuits was filed against DeshaunWatson (“Mr. Watson”), he has been adamant that he did not engage in any of the improperconduct that has been alleged. At the same time, he and his defense team have insisted that theyadamantly oppose, condemn, and disapprove of any type of sexual misconduct against women.Legitimate claims should be reported to authorities, taken seriously, and their proponents treatedrespectfully.However, in the few days since Mr. Watson has learned the identity of his accusers, hislegal team has already uncovered evidence that numerous allegations in this onslaught of cases aresimply not true or accurate. For example: After the massage therapy sessions with Mr. Watson, 8 plaintiffs bragged about,praised, and were excited about massaging Mr. Watson; 7 plaintiffs willingly worked or offered to work with Mr. Watson after theiralleged incidents; 3 plaintiffs lied about the number of sessions they actually had with Mr.Watson; 3 plaintiffs lied about their alleged trauma and resulting harm; 5 plaintiffs told others they wanted to get money out of Mr. Watson; and 5 plaintiffs have scrubbed or entirely deleted their social media accounts.4/19/2021 8:56 AM Marilyn Burgess - District Clerk Harris CountyEnvelope No. 52573145By: Wanda ChambersFiled: 4/19/2021 8:56 AM 2It was not until the plaintiffs saw an opportunity for a money grab that they changed theirstories to convert therapy sessions they bragged about to friends and family to something muchmore nefarious. Innocent questions about whether the therapists were comfortable with thetherapy Mr. Watson sought evolved into sexual inuendo that the plaintiffs used to bolster theirclaims for money. For example, in the first lawsuit filed, Plaintiff Ashley Solis implies that Mr.Watson’s question—asking if she “was comfortable with certain areas [his] organization is makinghim get worked on”—was somehow sexually suggestive. That same question, however, posed toa therapist not seeking to exploit Mr. Watson, was perceived as it was intended: a legitimatetherapeutic inquiry.1 Ms. Solis’s skewed perception of Mr. Watson’s legitimate and innocentquery became a prototype for the assembly line of similar allegations in subsequent lawsuits.These lawsuits are replete with mischaracterizations of Mr. Watson’s conduct. These rangefrom being misleading, to fraudulent, to slanderous. Importantly, only two of the twenty-twolawsuits allege that Mr. Watson forced any type of sexual activity—an allegation Mr. Watsonagain vehemently denies. And even at this early stage of the litigation, the evidence obtained bythe defense clearly supports Mr. Watson’s denial of these allegations of force. As Plaintiff SheneéLawson’s business manager put it, this is “not extortion. It’s blackmail.” Unfortunately, twenty-one other women have decided to join her.1 See Exhibit 1. 3PROBLEMS WITH THE PLAINTIFFS’ ALLEGATIONS Mr. Watson received the plaintiffs’ names less than a week ago. Based on what we havebeen able to determine so far, these plaintiffs are not victims of any type of misconduct, much lesssexual misconduct: A. After the massage therapy sessions with Mr. Watson, Plaintiffs bragged about, praised,and were excited to massage Mr. Watson. Plaintiff Sheneé Lawson claims in the lawsuit that she is “disgusted” by Mr.Watson. Yet, after her therapy session with him, she bragged to friends and familymembers about massaging Mr. Watson and told them that she thinks he is a kindperson. A security guard at the spa where Mr. Watson received a massage stated thatPlaintiff Tangee Johnson was happy and laughing after her interactions with Mr.Watson. She was excited about having worked on him and did not want any othertherapist to work on him. According to a security guard present at the spa, after one of Plaintiff MarchelleDavis’s sessions with Mr. Watson, Ms. Davis was laughing and appeared in goodspirits. Another witness characterized Ms. Davis as “jolly” after working with Mr.Watson. And Ms. Davis told multiple family members that she would massage Mr.Watson again. She even told people that while she was not “into men,” “his bodyis beautiful and soft” and that if she were not a lesbian, she would have “jumpedon” Mr. Watson. Plaintiff Chelcie Bell fails to explain that after the first two therapy sessions—which she alleges were increasingly “uncomfortable”—she willingly invited Mr.Watson to come to her house for the last two therapy sessions. Plaintiffs Kyla Hayes, Robin Caicedo, and Kimberly Brice omitted that after theirsessions with Mr. Watson, they told him that they would gladly work with himagain. In fact, Kimberly Brice reported to a close relative that she was thrilled tohave had the opportunity to massage Deshaun. Plaintiff Erica Chapman claims that after the initial therapy session, Mr. Watsonhounded her about setting up another session. She fails to explain that she eagerlyshowed up to Mr. Watson’s house to give him another massage before he even hada chance to book an appointment. B. Plaintiffs willingly worked, or offered to work, with Mr. Watson after the allegedincidents. At least five of the plaintiffs chose to work with Mr. Watson even after they claimhe acted offensively and aggressively in prior sessions: Erica Chapman, KaylanHurrington, Rebecca Nagy, Toi Garner, and Chelcie Bell. This, of course, raisesthe question of why they would agree to follow-up therapy sessions when theyclaim their experiences made them feel like they “wanted to vomit” and causedthem to “no longer accept massage clients, for fear of a repeat of this type ofharassment.” Plaintiff Tangee Johnson claims she was “fearful” and felt “violated, terrified anddisgusted” after her therapy sessions with Mr. Watson. She does not explain whythen, on more than one occasion, she messaged him after his football games tocheck in on him and asked to massage him again. Contrary to Plaintiff Krystle Da Rosa’s claim that she was so “disturbed” by whatallegedly occurred that she chose not to contact Mr. Watson about receiving therest of the payment for the session, the evidence shows that after the allegedincident she did attempt to contact Mr. Watson and even asked to work with himagain. In stark contrast to Plaintiff Kaylan Hurrington’s statement that after the allegedincident she told Mr. Watson that she “would not work for him” and “has not beenable to move on from these experiences,” she contacted Mr. Watson multiple timestelling him that she was attracted to him and wanted to go out on dates with him.C. Plaintiffs lied about the number of sessions they actually had with Mr. Watson. The following plaintiffs failed to mention they had more therapy sessions with Mr.Watson than what they pleaded: Kyla Hayes; Robinitta Miller; and Robin Caicedo.Presumably, these plaintiffs minimized their interactions with Mr. Watson becausethese facts undermine their allegations.D. Plaintiffs lied about their alleged trauma and resulting harm. Plaintiff Ashley Solis claimed during a news conference that she “can no longerpractice the profession that [she] love[s] the most without shaking during asession.” Yet, publicly available information shows that she has provided multiplemassages after the alleged incident with Mr. Watson. Indeed, not only is she stillaccepting clients, but according to those who have worked with her, she did notshow any signs of trauma during these sessions. While Plaintiff Toi Garner claims that “[b]y the end of the massage, she wassweating” and “there was nowhere for her to go,” she neglects to mention she hadmultiple family members in the home and nearby during both therapy sessions. Plaintiff Marchelle Davis alleges that “she was alone at the spa and feared for herlife” during her therapy sessions with Mr. Watson. However, a security guard hiredby the spa was present at the spa at all times and capable of intervening if anincident had, in fact, occurred. E. Plaintiffs told others they wanted to get money out of Mr. Watson. Plaintiff Marchelle Davis told close family members that if Mr. Watson’s attorneyhad paid her, she would have supported him instead of suing him. She also told herfamily that she had contemplated blackmailing Mr. Watson. Plaintiff Krystle Da Rosa told a witness that the only reason she was gettinginvolved in the lawsuit was for money. She even laughed about it and stated thatshe wanted to “get in on the action.” Plaintiff Sheneé Lawson admittedly sought to “blackmail” Mr. Watson before shefiled suit. She asked him to pay her $30,000 for “indefinite silence” because herencounter would be “embarrassing” if revealed. More importantly, when Mr.Watson’s marketing manager, Bryan Burney, asked her whether she was claimingthat something happened against her will, she confirmed that everything thatoccurred was consensual. Finally, she told Mr. Burney that she wanted a copy ofthe NDA that she and Mr. Watson signed because she did not want people in herindustry to know she had provided oral sex to her massage client. Evidence of herconcerns is contained in Mr. Burney’s affidavit and a contemporaneous taperecording of a phone conversation. Witnesses state that Plaintiff Kimberly Brice has a history of “forcing herself oncelebrities,” “chasing celebrities,” and “running behind high profile athletes.” Theyalso describe her as being “out for money,” and “a money grabber.” During one of the press conferences Mr. Buzbee held regarding the case, PlaintiffAshley Solis claimed that she was not filing suit for monetary reasons but ratherbecause “[t]his is about having [her] voice heard. It is about having other survivor’svoices heard.” Belying her assertion though, Ms. Solis would have abandoned hervoice and being the voice of other alleged “survivors” if Mr. Watson would agreeto pay her $100,000. F. Plaintiffs have scrubbed, or entirely deleted, their social media accounts and therelevant evidence they contained.Each of the plaintiffs’ petitions contain a paragraph warning Mr. Watson to preserverelevant evidence, including digital information. Without question, Mr. Watson has and willcontinue to do so. However, the plaintiffs have failed to heed their own warning. At least fourplaintiffs, Krystle Da Rosa, LaToya Johnson Hanks, Tavi Turner, and Marchelle Davis, have 6altered the accounts where they advertised the services that Mr. Watson acquired. Before theirnames became public, their accounts contained pictures that are inconsistent with the image theyportray through their petitions. These items are no longer posted to their accounts. PlaintiffKimberly Brice took the destruction of evidence even further by completely deleting her Instagramaccount, which again is the account she claims to use to market her services and the one that Mr.Watson used to contact her and hire her for a massage.GENERAL DENIALPursuant to Texas Rule of Civil Procedure 92, Watson generally denies the allegations andclaims set forth in Plaintiff’s Original Petition and demands strict proof thereof by a preponderanceof the evidence and clear and convincing evidence, as required by the Constitution and laws of theState of Texas.JURY DEMANDMr. Watson requests a jury trial and submits the applicable fee contemporaneous with thisfiling.PRAYERBecause the Plaintiff’s claims lack a basis in law or fact, Mr. Watson prays that she takenothing by reason of this suit, that all relief requested by Plaintiff be denied, that Mr. Watsonrecovers his costs of court and expenses, and for all other relief to which he is entitled. 7Respectfully submitted,RUSTY HARDIN & ASSOCIATES, LLP/s/ Rusty HardinRusty HardinState Bar No. 08972800Letitia D. Quinones (Of Counsel)State Bar No. 24008433Lara HollingsworthState Bar No.00796790Leah GrahamState Bar No. 24073454Rachel LewisState Bar No. 241207621401 McKinney Street, Suite 2250Houston, Texas 77010Telephone: (713) 652-9000Facsimile: (713) 652-9800rhardin@rustyhardin.comlquinones@rustyhardin.comlhollingsworth@rustyhardin.comlgraham@rustyhardin.comrlewis@rustyhardin.comAttorneys for DefendantDeshaun WatsonCERTIFICATE OF SERVICEI certify that a true and correct copy of the foregoing instrument has been served upon thePlaintiff by eservice on April 19, 2021, pursuant to Rule 21a./s/ Rusty HardinRusty Hardin Quote Link to comment Share on other sites More sharing options...
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