Doe v. Sequoia Capital Operations LLC et al

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
AMBER DOE 	CIVIL ACTION
VERSUS 	NO. 25-1803 C/W 25-01754
SEQUOIA CAPITAL OPERATIONS LLC 	SECTION “H”(4)
REPORT AND RECOMMENDATION
This action commenced on September 2, 2025, when the court received a pro se complaint
by Plaintiff Amber Doe. R. Doc. 1. The Plaintiff was granted leave to proceed in forma pauperis
in the action. On September 5, 2025, another complaint filed by Doe was transferred from the
Western District of Kentucky to this Court and is a duplicate of the complaint already pending
here.1 Now upon review of the pro se complaints, the undersigned recommends that the actions
be dismissed as legally frivolous pursuant to Title 28 U.S.C. §1915(e)(2).
I. 	Factual and Procedural Background
A. 	Complaint
Plaintiff Amber Doe filed the subject action and lodged a 290-page complaint against
Michael Lewis Goguen, a Whitefish engineer and businessman and former partner with Sequoia
Capital.2 R. Doc. 1 at 2. Doe seeks to recover a range of damages between $889 million and 1.207
billion dollars for alleged severe physical, psychological, emotional, reputational, and economic
1 See Amber Doe v. Sequoia Capital Operations, Western District of Kentucky, 25-01954 H(4). Notably she deleted
two pages from the original complaint filed in this court as it contains 288 pages and not 290.
2 Doe names the following additional Sequoia Companies as wholly owned subsidiaries or affiliates. There are
however no individual allegations against them. Sequoia Capital Franchise Partners, L.P., Sequoia Capital IX, L.P.,
Sequoia Entrepreneurs Annex Fund, L.P. Sequoia Heritage, LLC, Sequoia Capital Growth III Principals Fund, LLC,
Sequoia Capital Franchise Fund, LLP., Sequoia Capital Growth Partners III, L.P. Sequoia Capital Growth Fund III,
L.P. Sequoia Capital Global Equities, LLC, Sequoia Capital India LLP, Sequoia Capital China Fund, L.P. Sequoia
Capital Canada LLP, Sequoia Capital Israel LLP, Sequoia Capital Consultants, Inc., Sequoia Fund Management (
cayman) Ltd. And Sequoia Capital Wealth Partners.
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harm. Id. at 283. She also seeks loss of earnings, medical expenses, pain and suffering, loss of
enjoyment of life, and other expenses. Id.
Although she is proceeding pro se, Doe further seeks reimbursement of reasonable
attorney’s fees in addition to court costs, expert witness fees, and protective security costs plus out
of pocket litigation expenses. Id. at 285. Finally, she seeks an expungement of all fraudulent
judgments, orders, vexatious litigant designations, and retaliatory rulings in the United States,
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Canada and International forums. Id. 286. She also sued a collection of lawyers3, law firms4, public
officials5, financial companies6 , media companies7, and various state8 and federal judges9.
Doe alleges various media entities including Vox Media, Fox Corporation, Fox News,
Rupert Murdoch, Bloomberg L.P., NBCUniversal, and MSNBC knowingly participated in
3 Quinn Emanuel Urquhart & Sullivan LLP and its named attorneys including John Quinn,
Kathleen Sullivan, Diane Doolittle, Bruce Van Dalsem, Kyle Batter, Michael F. Grady, Cristopher
Tayback, Will C. Price, Mark Holsher, Suong Nguyen, Joseph Sarles, Patrick Doolittle, Margaret
Caruso, Michael Lifrak, Megan Kerr, Sara Cork, Sara Pollack, Alex Gerbi, Ted Greeno, Aidan
O’Rourke, Gregory Pantlin, Harry Olivar Alex Spiro, Lenczner Slaght, Herb Fox Law Offices.
4 Glaser Weill, LLP, Patricia Glaser, Jill Basinger, Goodwin Procter, Anthony McCuker, Wilson
Sonsini Goodrich & Rosati LLP, Keith Eggleton, Kirkland & Ellis via David Klein, Baker
Marquart/Waymaker LLP through Ryan Baker and Christopher Reynolds, Lenczner Slaght LLP
and its attorneys Monique Jilesen and Sahar Talebi, Paoli & Purdy, William Paoli, Court Purdy,
Bisnar Chase Personal Injury Lawyers LLP, Brian Chase, Scott Ritsima, Brown & Charbonneau
LLP, Greogroy Brown and Sherman Law, Richard Sherman, The law Offices of Rivers J. Morrell
III , Rivers J. Morrell III, Day, Day & Brown, Alan Brown and Nemeck & Cole LLP, Frank W
Nemecek, Jonathan B. Cole, Marshall Cole, Michael W. Feenberg, Michael McCarthy, Mark
Schaeffer, Claudia Stone and Marta Alcumbrack and Herb Fox Law Offices.
5 California Attorney General Rob Bonta, Governor Gavin Newsom, Judicial Council Officials,
State Bar Representatives, Civil Rights Commission Members and Regulatory Agency Personnel
in their official capacity.
6 Two Bear Capital and its affiliates including Two Bear Capital Operations LLC, Two Bear
Ranch, Two Bear Farm, Two Bear Air Rescue Foundation, Two Bear Air 1, LLC, Two Bear
Security LLC, Crystal Slopeside LLC, Valley Oak LLC, Whitefish Frontiers LLC, Proof Research
Inc., and the Michael L. Goguen Trust.
7 New York Post, Vox Media, Fox Corporation, Fox News, Rupert Murdoch, Bloomberg L.P.
NBCUniversal and MSNBC.
8 State Court Judge Stephanie Bowick, Judge Nina Shapirshteyn,
9 Judge John Grandsaert, Judge Read Amble, Judge Danny Chou, Judges Cory Gilmore, Judges
Barbara Conway, Judge Nico Dourbetas, Judge Laura Swain, Magistrate Judge Steve Kim, District
Judge Maame Frimpong, Judge Donald Molloy, Judge David Carter.
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coordinated 	defamation, 	psychological 	warfare, 	and 	reputational 	sabotage 	by 	publishing
enterprise-approved propaganda that smeared her credibility. Id. at 10.
Doe identifies as a Canadian citizen and sex trafficking survivor. R. Doc. 1 at 1. Doe
complains that for over two decades she had been stalked, trafficked, raped, tortured, mutilated,
silenced, and defrauded across borders by a “coordinated criminal conspiracy”. 	Id. at 2. Doe
alleges that she was originally trafficked by a family member into the hands of the Hells Angels
at age fifteen and then funneled into a high-end international sex trafficking circuit marketed as
elite modeling. Id. at 21. Doe claims that she was trafficked through strip clubs, luxury properties,
and sporting events. Id.
The trafficking according to Doe was at the hands of billionaire pedophiles and took place
in the Virgin Islands and Texas where she met Michael Goguen who allegedly transported her via
aircraft and subjected her to forced sexual servitude. R. Doc. 1 at 21. She alleges that she settled
her suit with Goguen for $40 million, but he paid only $10 million of the agreed to amount. Id. at
25. She acknowledges that from 2003 through 2025 she filed multiple federal civil rights and
trafficking lawsuits in California, New York, D.C. and Montana which were all wrongfully
dismissed according to Doe.10 Id. at 23. She claims that each of the dismissals entered were based
on fraud and fraudulent testimony. See id.
10 See Baptiste v. Vox Media, et al., No. 1:23-cv-02161 (D.D.C. Feb. 2, 2024); Doe v. Sequoia
Capital, et al., No. CV 23-88-M-DWM (D. Mont. Oct. 17, 2023); Doe v. Sequoia Capital, No.
2:23-CV-6439-MEMF (SK) (C.D. Cal. Oct. 17, 2023); Doe v. Sequoia Capital, No. 23-CV-5881
(LTS) (S.D.N.Y. Aug. 14, 2023); Doe v. Quinn Emmanuel, No. 2:23-CV-4723-MEMF (SK) (C.D.
Cal. June 16, 2023); Doe v. Goguen, No. 2:23-CV-2280-MEMF (SK) (C.D. Cal. May 22, 2023).
it appears Plaintiff has filed identical complaints, in addition to this pending action. Doe v. Sequoia
Capital Operations, LLC, No. 1:25-cv-14707-ESK-MJS (D.N.J., complaint filed August 18,
2025); Doe v. Sequoia Operations LLC, No. 1:25-CV-2566 (UNA) (D.D.C., complaint filed Aug.
5, 2025); Doe v. Sequoia Operations LLC, No. 8:25-CV-2003 (TPB) (CPT) (M.D. Fla., complaint
filed July 30, 2025). For her extreme efforts, Plaintiff has earned the recognition of a vexatious
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Doe has now filed suit in this Court and alleges that jurisdiction would also be proper in
each district she was trafficked including Southern District of New York, Eastern District of New
York, District of New Jersey, District of Pennsylvania, the Northern District of California, the
Northern District of Texas, the District of Columbia, the District of the Virgin Islands, and DOR.
Id. at 5.
Doe seeks to allege “universal jurisdiction” and contends that this case is not truly a civil
complaint R. Doc. 1 at 18. She generally alleges that the Defendants operated a criminal syndicate
in various states including Louisiana. Id. at 3. In addition to alleging civil rights violations, she
seeks to pursue claims under various federal and state statutes as well as international laws. The
state statutes which Doe seeks relief on are criminal statutes of Human Trafficking11, aggravate
rape12, public bribery13, Malfeasance in Office14, and Louisiana Human Trafficking Prevention
Act.15 Having set forth in summary form Doe’s allegations, the Court will proceed with its
frivolous review.
II. 	Standard of Review
Title 28 U.S.C. §1915(e)(2) provides that if the allegations in a in forma pauperis complaint
are frivolous or malicious, fail to state a claim upon which relief may be granted, or seek monetary
litigant from the Superior Court of California and the California State Bar. See Doe v. Sequoia
Capital Operations LLC, No. 25-cv-6169-LTS, Dkt. 8, at 3, 7, (S.D.N.Y. Aug. 20, 2025).
11 La. R.S. 14:46.2
12 La. R.D. 14.42.
13 La. R.S. 14:118.
14 La. R.S. 14:134.
15 La. R.S. 46.2161.
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relief from a defendant who is immune from such relief, the Court shall dismiss the case at anytime.
28 U.S.C. § 1915(e)(2). To survive the pleading stage, a civil complaint must set forth “sufficient
factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v.
Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)).
And to prevent “abusive or captious litigation,” the IFP statute “authorizes federal courts
to dismiss” any action that “is frivolous or malicious.” Neitzke v. Williams, 490 U.S. 319, 325
(1989) (cleaned up). Frivolous complaints are those that “lack [ ] an arguable basis either in law
or in fact.” Id. And a “complaint is malicious if it suggests an intent to vex defendants or abuse the
judicial process by relitigating claims decided in prior cases.” Young Yil Jo v. Six Unknown Names
Agents, No. 1:06-cv-01714, 2006 WL 3483429, at *1 (E.D. Cal. Dec. 1, 2006).
III. 	Analysis
A. Jurisdiction
Doe, a “multiethnic Canadian citizen with American ancestry” who resides in California,
alleges that she was trafficked at the hands of billionaire pedophiles. R. Doc. 1 at 21. She contends
that the trafficking took place in the Virgin Island, and Texas where she met Michael Goguen, also
a resident of California, who transported her via aircraft and subjected her to forced sexual
servitude.16 Id.
Federal courts, unlike state courts, are courts of limited jurisdiction which can only
adjudicate those cases which the United States Constitution or Congress authorize them to
adjudicate. Kokkonen v. Guardian Life Ins. Co., 511 U.S. 375, 377, 114 S. Ct. 1673, 128 L.Ed.2d
391 (1994). Congress has only authorized federal jurisdiction in cases which present a federal
16 Doe alleges that Goguen is a resident of Montana, California and New York. R. Doc. 1 at 8.
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question as set forth by 28 U.S.C. § 1331 or where there is complete diversity of citizenship and
the amount in controversy exceeds $75,000 as set forth by 28 U.S.C. § 1332. A party seeking to
invoke federal subject matter jurisdiction has the burden of establishing that jurisdiction exists.
Data Disc, Inc. v. Systems Technology Assocs. Inc., 557 F.2d 1280 (9th Cir.1977).
1. 	Diversity of Citizenship
Doe has failed to allege complete diversity of citizenship as required by 28 U.S.C. § 1332.
In the complaint, she alleges that Goguen is also a resident of California and Quinn Emanuel
Urquhart is a law firm headquartered in Los Angles California although not specified by Doe. Doe
also simply lists Sequoia Capital Operations, LLC and its subsidiaries but fails to identify where
they were incorporated or where they operate.
Doe further identified eight additional law firms and, in most instances generally included
the names of the lawyers that she believes wronged her. R. Doc. 1 at 8,9. Regardless of this fact,
complete diversity does not exist because at least two defendants and Doe reside in California.
Notably, there is no resident of the State of Louisiana that would afford this court any jurisdiction
based on diversity. Therefore, Doe’s lawsuit should be dismissed based on diversity citizenship
because this court lacks subject matter jurisdiction.
a. Breach of the Covenant of Good Faith and Fair Dealing
Doe also seeks to sue each firm that she claims to have retained to represent her for breach
of the covenant of good faith and fair dealing. R. Doc. 1 at 103-106. Doe particularly contends
that she entered into written retainer agreements with eleven different firms17 who owed her an
17 Glaser Weil, LLP, Patricia Glaser, Jill Basinger; Bisnar Chase LLP: Brian Chase, Scott Ritsema; Sherman
Law: Richard Sherman; Paoli & Purdy LLP: William Paoli Court Purdy; Brown & Charbonneau LLP: Gregory
Brown and Associates: The Law Firm of Rivers J. Morrell III: Rivers Morrell; Quinn Emanuel Urquhart &
Sullivan LLP: Diane Doolittle, John B. Quinn, Bruce Van Dalsem, Kyle Batter and Associates; Wilson Sonsini
Goodrich & Rosati LLP, Keith Eggleton; Goodwin Procter LLP, Anthony McCusker: Nemecek & Cole: Frank
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implied covenant of good faith and fair dealing. Id. 	Doe contends that the duty was breached
generally because the Defendants abandoned or sabotaged her legal claims under coercion and
influence from Michael Goguen. Id. 	Doe further alleges that the lawyers concealed conflicts of
interests, failed to file appeals, suppressed evidence, and intentionally delayed meritorious
proceedings. Id. at 105.
Doe also claims that the attorneys participated in the enforcement of a fraudulent California
judgment and Ontario Mareva injunction which retroactively deprived her of the initial $10
million dollar benefit. R. Doc. 1 at 105. Doe claims that the “attorneys” engaged in retaliatory ex
parte filings, strategic gag orders, and false statements before California and Ontario courts. Id.
Finally, she claims that the “lawyers” failed to protect her civil rights, including the rights
guaranteed under the U.S. Constitution and international human rights law. Id.
Although not pled by Doe, each of the law firms except Lenczner Slagth are located in
California. As stated previously, Doe is also a resident of California. The claim for breach of
covenant of good faith and fair dealing is based upon the law of the state where the contract was
created, or the law identified in the contract.18
Under California law, every contract, including commercial leases generally, “imposes
upon each party a duty of good faith and fair dealing in its performance and its enforcement.”
Carma Developers (Cal.), Inc. v. Marathon Development California, Inc. 2 Cal. 4th 342, 371–
372, 6 Cal.Rptr.2d 467, 826 P.2d 710 (1992), quoting Foley v. Interactive Data Corp. 47 Cal.3d
654, 683–684, 254 Cal. Rptr. 211, 765 P.2d 373 (1988).
Nemecek, John Cole, Claudia Stone, Marta Alcumbrac, and Lenczner Slagth LLP: Monique Jilesen, Sahar Telbi,
Barbara Conway, and Cory Gilmore.
18 Notably Doe failed to allege which law governs the purported retainer agreements.
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However, there is no diversity of citizenship Doe and Glaser Weil, LLP, Patricia Glaser,
Jill Basinger; Bisnar Chase LLP: Brian Chase, Scott Ritsema; Sherman Law: Richard Sherman;
Paoli & Purdy LLP: William Paoli Court Purdy; Brown & Charbonneau LLP: Gregory Brown
and Associates: The Law Firm of Rivers J. Morrell III: Rivers Morrell; Quinn Emanuel Urquhart
& Sullivan LLP: Diane Doolittle, John B. Quinn, Bruce Van Dalsem, Kyle Batter and Associates;
Wilson Sonsini Goodrich & Rosati LLP, Keith Eggleton; Goodwin Procter LLP, Anthony
McCusker: Nemecek & Cole: Frank Nemecek, John Cole, Claudia Stone, Marta Alcumbrac, and
Cory Gilmore, as they are residents of California. Further, there is no connexity between
Louisiana and the alleged contractual breaches. Therefore, this Court lacks diversity jurisdiction
to hear this claim, and it should therefore be dismissed.
b. Breach of Fiduciary Duty
In addition to her claims against the eleven firms, she seeks to assert a breach of fiduciary
duty claim arising out of the attorneys’ representation. R. Doc. 1 at 106-109. She names the same
law firms and added Goodwin Procter LLP, Anthony McCusker: Marshall R. Cole, Michael
Feenberg, Michael McCarthy, Mark Schaeffer, Claudia Stone, Marta Alcumbrac, Kathleen
Sullivan, Michael Grady, Christopher Tayback, William Price, Mark Holsher, Suong Nguyen,
Joseph Sarles, Patrick Doolittle Margaret Caruso, Michael Lifrak, Megan Kerr, Sara Pollack,
Alex Gerbi, Ted Greeno, Aidan O’Rourke, Gregory Pantlin; Kirkland & Ellis LLP, David Klein;
Baker Marquart LLP/ Waymaker LLP, Ryan Baker, Christopher Reynolds, Day, Day & Brown,
Alan Brown; Lenczner Slaght LLP, Monique Jilesen, and Sahar Talebi as defendants. Id.
Doe contends that these law firms and attorneys again abandoned or sabotaged her claims;
concealed conflicts of interest, failed to file appeals, and suppressed evidence. R. Doc. 1 at 105.
She contends that each of these firms participated in enforcement of a fraudulent California
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judgment and Ontario injunction. Id. She also contends that these attorneys engaged in retaliatory
ex parte filings and failed to protect her civil rights. Id. She does not state with particularity which
lawyers and firms she retained as opposed to those which were retained by Michael Goguen, or
Sequoia Capital.
As stated previously, complete diversity of citizenship does not exist. Doe and the Glaser
Weil, LLP, Patricia Glaser, Jill Basinger; Bisnar Chase LLP: Brian Chase, Scott Ritsema;
Sherman Law: Richard Sherman; Paoli & Purdy LLP: William Paoli Court Purdy; 	Brown &
Charbonneau LLP: Gregory Brown and Associates: The Law Firm of Rivers J. Morrell III: Rivers
Morrell; Quinn Emanuel Urquhart & Sullivan LLP: Diane Doolittle, John B. Quinn, Bruce Van
Dalsem, Kyle Batter and Associates; Wilson Sonsini Goodrich & Rosati LLP, Keith Eggleton;
Goodwin Procter LLP, Anthony McCusker: Nemecek & Cole: Frank Nemecek, John Cole,
Claudia Stone, Marta Alcumbrac, David Klein; Baker Marquart LLP/ Waymaker LLP, and Cory
Gilmore, are residents of California. There is no connexity between Louisiana and the alleged
contractual breaches. Therefore, this Court lacks jurisdiction to hear this claim and it should
therefore be dismissed.
Additionally, as for Doe’s claims against Kirkland & Ellis LLP, David Klein in New York,
Lenczner Slaght LLP, Monique Jilesen, and Sahar Talebi, it is unclear whether they represented
her or defended against claims that she filed. She also fails to allege a statutory basis for this
Court’s jurisdiction over the Canadian law firm and its attorneys.
Personal jurisdiction is “‘an essential element of the jurisdiction of a district ... court,’
without which the court is ‘powerless to proceed to an adjudication.’” Ruhrgas AG v. Marathon
Oil Co., 526 U.S. 574, 584, 119 S. Ct. 1563, 143 L.Ed.2d 760 (1999) (quoting Employers
Reinsurance Corp. v. Bryant, 299 U.S. 374, 382, 57 S. Ct. 273, 81 L. Ed. 289 (1937)). Before a
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court can exercise personal jurisdiction over a non-resident defendant, a two-part inquiry must be
made. First, the court must find that the forum state's long-arm statute authorizes the exercise of
jurisdiction. 	Pritzker v. Yari, 42 F.3d 53, 60 (1st Cir.1994). Second, the court must determine
whether the exercise of jurisdiction pursuant to the long-arm statute complies with the Due
Process Clause of the United States Constitution. Id. Louisiana’s long-arm statute, Louisiana long
arm statute, La. Rev. Stat. Ann. 13:3201 (West Supp.1985). La. R.S. 13:3201 permits jurisdiction
over non-resident defendants to the extent allowed.
Due process requires that the Defendant must have sufficient contacts with the forum state
so that subjecting the defendant to the forum's jurisdiction does not offend “traditional notions of
fair play and substantial justice.” United Elec., Radio & Mach. Workers of Am. v. 163 Pleasant
St. Corp., 960 F.2d 1080, 1087 (1st Cir.1992) (citing Int'l Shoe Co. v. Washington, 326 U.S. 310,
316, 66 S. Ct. 154, 90 L. Ed. 95 (1945)). The applicable minimum contacts standard depends on
whether the forum is exercising general jurisdiction or specific jurisdiction. Archibald v.
Archibald, 826 F. Supp. 26 (D. Me. 1993).
General jurisdiction can be asserted over a non-resident defendant when the defendant's
activities with the forum state are “substantial” or “continuous and systematic.” Id. When the
alleged contacts fail to support the exercise of general jurisdiction, the contacts may nonetheless
support the exercise of specific jurisdiction. Swiss Am. Bank, Ltd., 274 F.3d at 623. Specific
jurisdiction “may be asserted where the cause of action arises directly out of, or relates to, the
defendant's forum-based contacts.” United Electrical, Radio & Machine Workers of Am v. 163
Pleasant St. Corp, 960 F.2d 1080, 1085 (1 st . Cir. 1992)
Whether specific jurisdiction exists “turns on an evaluation of ‘the relationship between
the defendant, the forum, and the litigation.’” Archibald, 826 F. Supp. at 30 (quoting Helicopteros
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Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 414, 104 S. Ct. 1868, 80 L.Ed.2d 404
(1984)). This relationship is examined by the application of a tripartite test which considers (1)
“whether the claim that undergirds the litigation directly relates to or arises out of the defendant's
contacts with the forum”; (2) “whether those contacts constitute purposeful availment of the
benefits and protections afforded by the forum's laws”; and (3) whether, overall, it is reasonable
to exercise jurisdiction in light of five factors that touch upon the fundamental fairness of
exercising jurisdiction. See Swiss Am. Bank, Ltd., 274 F.3d at 620–621. All three prongs of the
tripartite test must be satisfied for this Court to exercise specific jurisdiction over Kirkland & Ellis
LLP, David Klein in New York, Lenczner, Slaght LLP, Monique Jilesen, and Sahar Talebi,
Canadian attorneys.
The Complaint fails to satisfy any of the factors required to have either general jurisdiction
or specific jurisdiction over these defendants as it lacks any allegations regarding same.
Therefore, Doe’s claims against Glaser Weil, LLP, Patricia Glaser, Jill Basinger; Bisnar Chase
LLP: Brian Chase, Scott Ritsima; Sherman Law: Richard Sherman; Paoli & Purdy LLP: William
Paoli Court Purdy; Brown & Charbonneau LLP: Gregory Brown and Associates: The Law Firm
of Rivers J. Morrell III: Rivers Morrell; 	Quinn Emanuel Urquhart & Sullivan LLP: Diane
Doolittle, John B. Quinn, Bruce Van Dalsem, Kyle Batter and Associates; Wilson Sonsini
Goodrich & Rosati LLP, Keith Eggleton; Goodwin Procter LLP, Anthony McCusker: Nemecek
& Cole: Frank Nemecek, John Cole, Claudia Stone, Marta Alcumbrac, Cory Gilmore, Marshall
R. Cole, Michael Feenberg, Michael McCarthy, Mark Schaeffer, Claudia Stone, Martha
Alcumbrac, Kathleen Sullivan, Michael Grady, Christopher Tayback, William Price, Mark
Holsher, Suong Nguyen, Joseph Sarles, Patrick Doolittle Margaret Caruso, Michael Lifrak,
Megan Kerr, Sara Pollack, Alex Gerbi, Ted Greeno, Aidan O’Rourke, Gregory Pantlin; Kirkland
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& Ellis LLP, David Klein; Baker Marquart LLP/ Waymaker LLP, Ryan Baker, Christopher
Reynolds, Day, Day & Brown, Alan Brown; Lenczner Slaght LLP, Monique Jilesen, and Sahar
Talebi should be dismissed.
c. 	Legal Malpractice and Intentional Infliction of Emotional Distress
Doe next alleges that Glaser Weil LLP, Patricia Glaser; Jill Basinger, Rivers J. Morrell III,
the Law Offices of Rivers Morrell III, Gregory Brown, Brown & Charbonneau LLP; 	William
Paoli, Paoli & Purdy LLP, Binsar Chase LLP, Brian Chase, Scott Ritsima, Richard Sherman;
Sherman Law, Diane Doolittle, Quinn Emanuel Urquhart & Sullivan, John Quinn, Michael Grady,
William Price, Christopher Tayback, Margaret Caruso, Patrick Doolittle, Michael Lifrak, Sara
Pollack, Megan Kerr, Alex Gerbi, Ted Greeno, Claudia Stone, Marta Acumbrac, Jonathan Cole,
Marshall Cole, Franck Nemecek, Michael Feen Berg, Michael McCarthy, Mark Schaeffer, Alan
Brown, Day, Day & Brown, Anthony McCusker (Goodwin Procter); Keith Eggleton (Sonsini),
David Klein ( Kirkland & Ellis), Ryan Baker, Christopher Reynolds (Baker Marquart LLP), now
(Waymaker LLP), Leczner Slagth LLP, Monique Jilesen, and Sahar Talebi were attorneys who
owed her a non-delegable duty to provide competent legal counsel. R. Doc. 1 at 109-116. 	She
alleges that these attorneys had a duty to avoid all conflicts of interest, preserve privileged
communications, and uphold the highest standard of care. Id. She also alleges that counsel should
have refrained from obstructing justice or furthering criminal conspiracies. Id.
However, a legal malpractice claim is based on the state law where the attorney practices.
The statute of limitations for legal malpractice claims in California states in pertinent part: “An
action against an attorney for a wrongful act or omission, other than for actual fraud, arising in the
performance of professional services shall be commenced within one year after the plaintiff
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discovers, or through the use of reasonable diligence should have discovered, the facts constituting
the wrongful act or omission, or four years from the date of the wrongful act or omission,
whichever occurs first.” (Laird v. Blacker (1992) 2 Cal.4th 606, 611, 7 Cal.Rptr.2d 550, 828 P.2d
691 (Laird ).) Thus, “section 340.6 states ‘two distinct and alternative limitation periods: one year
after actual or constructive discovery, or four years after occurrence (the date of the wrongful act
or omission), whichever occurs first.’ Neither of these limitations’ periods are addressed in the
complaint.
This Court does not have subject matter or personal jurisdiction over the legal malpractice
claims because they are involving California law and parties. Therefore the claims against Glaser
Weil LLP, Patricia Glaser; Jill Basinger, Rivers J. Morrell III, the Law Offices of Rivers Morrell
III, Gregory Brown, Brown & Charbonneau LLP; 	William Paoli, Paoli & Purdy LLP, Bisnar
Chase LLP, Brian Chase, Scott Ritsima, Richard Sherman; Sherman Law, Diane Doolittle, Quinn
Emanuel Urquhart & Sullivan, John Quinn, Michael Grady, William Price, Christopher Tayback,
Margaret Caruso, Patrick Doolittle, Michael Lifrak, Sara Pollack, Megan Kerr, Alex Gerbi, Ted
Greeno, Claudia Stone, Marta Acumbrac, Jonathan Cole, Marshall Cole, Franck Nemecek,
Michael Feen Berg, Michael McCarthy, Mark Schaeffer, Alan Brown, Day, Day & Brown,
Anthony McCusker (Goodwin Procter); Keith Eggleton (Sonsini), David Klein ( Kirkland &
Ellis),Ryan Baker, Christopher Reynolds (Baker Marquart LLP), now Waymaker LLP), Leczner
Slagth LLP, Monique Jilesen, Sahar Talebi. 	Notably, Doe points out that the applicable duties
arise as a result of Ontario, California and New York laws and rules not Louisiana. The legal
malpractice claims should therefore be dismissed.
d. 	Intentional Infliction of Emotional Distress and Deceit
Doe also alleges that Sequoia Capital, Michael Lewis Goguen, Two Bear Capital, Two
Bear Ranch, Quinn Emanuel Urquhart & Sullivan, Diane Doolittle, John Quinn, Bruce Van
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Dalsem, Kyle Batter, Patricia Glaser, Glaser Weil, Jill Basinger, Gregory Brown, Brown &
Charbonneau, William Paoli, Paoli & Purdy, Bisnar Chase, Brian Chase, Scott Ritsima, Richard
Sherman, Sherman law Anthony McCusker, Goodwin Procter, Wilson Sonsini, Goodrich &
Rosati, Nemecek & Cole, Michael Strickland, Sitrick & Company, Chris Reynolds, Brian Baker,
Alex Gerbi, Ted Greeno, Aiden O’Rourke, John Quinn Diane Doolittle, Bruce Van dalsem, Kyle
Batter, Patrica Glaser Jill Basinger, Franck Nemecek, Alex Spiro, John Cole, Marshall Cole Marta
Alcumbrac, Claudia Stone, Brian Chase, Scott Ritsima, Sara Cork, Gregory Brown, Sara Pollack
Joseph Sarles, Michael Lifrack Patrick Doolittle, Rivers Morrell III, Alan Brown intentionally
inflicted emotional distress upon her. R. Doc. 1 at 117-121. She contends that her claim is
pursuant to New York law. Id. She contends that they engaged in repeated acts of sexual slavery,
deliberate legal sabotage, fraudulent legal documents, and abandonment by her legal counsel. Id.
at 118. 	She alleges that they physical stalked her and engaged in systemic media retaliation and
froze her bank accounts. Id. 	She also contends that the Defendants engaged in deceit by making
false representations to the courts., forging documents, misrepresenting conflicted attorneys, and
issuing defamatory statements. Id. at 140-143.
Like the breach of fiduciary duty and the breach of covenant of good faith and fair dealing
and for the same reasons detailed above, the Court does not have subject matter and personal
jurisdiction over these claims. There is no connexity to Louisiana as the Plaintiff nor the
Defendants are residents of this state, nor is there any allegation that the Defendants have the
necessary minimum contacts with Louisiana. Therefore, Doe’s intentional infliction of emotional
distress claim and deceit claim should be dismissed.
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e. 	Negligent 	Supervision/Negligent 	Direction, 	Willful 	and 	Wanton
Misconduct, Gross Negligence, and Personal Injury
Doe alleges that Sequoia Capital, Sequoia Capital Operations, Two Bear Capital, Two Bear
Ranch, Quinn Emanuel Urquhart & Sullivan, John Quinn, Diane Doolittle, Bruce Van Dalsem,
Kyle Batter, Glaser Weil, Patricia Glaser, Kill Basinger, Goodwin Procter, Anthony McCusker,
Wilson Sonsini Goodrich & Rosati, Paoli & Purdy, William Paoli, Bisnar Chase, Brian Chase,
Scott Ritsima, Nemecek & Cole LLP, Brown & Charbonneau LLP, Gregory Brown, Sherman
Law, Richard Sherman, Sitrick & Company, and Michael Sitrick negligently supervised their
employes. R. Doc. 1 at 121-125, 125-129. She alleges that the Defendants did not regulate their
agents, attorneys, or contractors who were involved in sensitive matters including legal
representation asset control and “public relations.” Id. According to Doe, these Defendants
should have known that their employees were engaged in human trafficking, judicial corruption
and bribery of judges, extortion, and retaliatory litigation. Id.
Doe also alleges that these Defendants engaged in willful and wanton misconduct, and their
gross negligence caused her personal injuries. R. Doc. 1 at 130-136, 136-140. According to the
complaint, 	these 	Defendants 	allegedly 	participated 	in 	the 	financing, 	perpetuation, 	and
concealment of cross-border human trafficking. Id. Doe further contends Defendants participated
in fraudulent legal proceedings and engaged in “surveillance, stalking, obstruction of justice, and
deprivation of medical care”. Id. She also asserts a claim of “media retaliation.” Id.
For the same reasons detailed in the previous claims, the Court does not have personal
jurisdiction over this claim. There is no connexity to Louisiana as the Plaintiff nor the Defendants
are residents of this state. Nor is there any allegation that the Defendants have the necessary
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minimum contacts to be sued in the State of Louisiana. 	Further, the claims against these non-
Louisiana Defendants are based on Canadian and New York law. 	Therefore, Doe’s negligent
supervision/direction, willful and wanton misconduct, gross negligence, and personal injury
claims should be dismissed. To the degree that Doe seeks to pursue these claims based on other
federal statutes, international laws or treaties, they have been addressed below.
2. 	Federal Question Jurisdiction
a. 	TPVA
Doe also attempts to raise federal question jurisdiction as she alleges that she filed this
lawsuit pursuant to the Trafficking Victims Protection Act (TPVA) Title 18 U.S.C. §§ 1581-1597.
R. Doc. 1 at 253-256.The TVPA permits civil remedies. See 18 U.S.C. § 1595. Pursuant to 18
U.S.C. § 1595,(a)n individual who is a victim of a violation of this chapter may bring a civil action
against the perpetrator (or whoever knowingly benefits, or attempts or conspires to benefit,
financially or by receiving anything of value from participation in a venture which that person
knew or should have known has engaged in an act in violation of this chapter) in an appropriate
district court of the United States and may recover damages and reasonable attorney’s fees.
Doe also asserts in Count 60, a claim under the same provision but entitled continued
human trafficking via judicial enterprise. Id. at 253. To plead trafficking under 18 U.S.C. § 1590,
a plaintiff must allege that the defendant (1) knowingly recruited, harbored, transported, provided
or obtained a person for labor, or (2) obstructed enforcement of section 1590. See Martinez v.
Calimlim, 651 F. Supp. 2d 852, 859 (E.D. Wis. 2009).
Here, Doe has not alleged, nor provided specific facts that would permit the court to infer,
that the pleading requirements for § 1590 are met. Generally, Doe alleges that Goguen participated
in a global sex trafficking scheme of which she was targeted. She does not allege how she was
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targeted but generally alleges that she somehow was trafficked by strip clubs, shell corporations,
luxury real estate, and private aviation via “elite modeling,” exotic dancing, and “Private VIP
events.” R. Doc. 1 at 3.
Additionally, she generally alleges that the “actors” operated a criminal syndicate and
deployed rape, coercion, enslavement, forged contracts and corrupted legal institutions in various
states including Louisiana. Id. However, Doe does not identify the actors of the syndicate and
merely alleges that Goguen was a participant. She further does not allege that Goguen obstructed
enforcement of § 1590. Doe generally alleges that the trafficking scheme include the use of New
Orleans based strip clubs, French Quarter elite model escort, and nightlife networks.
She claims that it included hospitality and tourism infrastructure, port and shipping
corridors, financial institutions, and corporate shells to perpetuate her exploitation. R. Doc. 1 at
14. Doe’s allegations are so generalized they lack factual grounding. 	While she generally claims
that the conduct occurred in Louisiana, she also claims that she was trafficked in Houston and
Dallas, California, New York, and Ontario Canada the complaint fails to contain sufficient factual
matter and rather contains labels and conclusions. Id. at 46. 	The complaint does not provide facts
for each defendants’ role in the alleged TPVA violation and nor does it allege that the defendants
obstructed enforcement of section 1590. 	The Court therefore finds that it lacks subject matter
jurisdiction over Doe’s TPVA claim and there is no federal question jurisdiction.
b. 	Civil Rico -18 U.S.C. §§ 1961-1968
Doe next asserts jurisdiction based upon the Civil Rico Statute pursuant to 18 U.S.C. §§
1961-1968. R. Doc. 1 at 59. Doe generally alleges that the “defendants” jointly constituted a
transnational association under Canadian law. Id. She proceeds to enumerate violations of various
laws including trafficking her sexually, physically and economically, laundering proceeds from
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trafficking, obstructing justice, destroying her credibility, and coercing her. 	Id. 	She does not
however set forth any facts to support the legal claims which she believes constitutes a violation
of the Civil Rico Law.
The Supreme Court has stated that a RICO enterprise is “a group of persons associated
together for a common purpose of engaging in a course of conduct,” which must be proven “by
evidence of an ongoing organization, formal or informal, and by evidence that the various
associates function as a continuing unit.” United States v. Turkette, 452 U.S. 576, 583, 101 S. Ct.
2524, 69 L.Ed.2d 246 (1981). 	There is also a requirement that the RICO defendant and RICO
enterprise must be distinct. Cedric Kushner Promotions, Ltd. v. King, 533 U.S. 158, 162–63, 121
S. Ct. 2087, 150 L.Ed.2d 198 (2001).
The Civil RICO statute creates a private right of action for “[a]ny person injured in his
business or property by reason of a violation of [RICO's criminal provisions].” 18 U.S.C. §
1964(c). Section 1962, in turn, makes it “unlawful for any person employed by or associated with
any enterprise engaged in, or the activities of which affect, interstate or foreign commerce, to
conduct or participate, directly or indirectly, in the conduct of such enterprise's affairs through a
pattern of racketeering activity.” Id. § 1962(c). A pattern of racketeering activity is defined to
include a variety of criminal offenses, such as wire fraud, mail fraud, commercial bribery, bank
fraud, and money laundering. Id. § 1961(1).
“Because plaintiff attempts to plead a Civil RICO claim, [the Court] must confront the
question of subject matter jurisdiction at the threshold of the case.” Purchase Real Est. Grp., Inc.
v. Jones, No. 05-CV-10859, 2010 WL 3377504, at *6 (S.D.N.Y. Aug. 24, 2010) (“[C]ourts should
look ‘with particular scrutiny’ at civil RICO claims to ensure that the RICO statute is used for the
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purposes intended by Congress.” (citing Goldfine v. Sichenzia, 118 F. Supp. 2d 392, 397 (S.D.N.Y.
2000))). “
Although Doe has a long list of defendants, the allegations in her complaint do not set forth
each Defendant’s role in the alleged enterprise in the purported racketeering activity. 	The only
possible action alleged is Goguen’s formulation of the enterprise, but there are no specific
allegations of the role that each defendant played in the racketeering. 	Doe alleges that the
racketeering conduct spanned across California, Texas, New York, Montana, Ontario, Alberta, and
British Columbia. She also alleges that there were international channels in Switzerland, Belize
and other financial secrecy jurisdictions to facilitate laundering. R. Doc. 1 at 60.
She also alleges generally that she was retaliated against and, that fabricate court orders
were transmitted, and that Defendants solicited her attempted murder. As stated previously, She
does not set forth specific allegations regarding which defendant engaged in the conduct about
what she complains. Her complaint is devoid of allegations that would comprise a requisite RICO
enterprise or a pattern of racketeering activity. 	These generalized allegations and deficiencies
render the Civil Rico claims “so patently without merit” as to warrant sua sponte dismissal of this
claim for lack of subject matter jurisdiction.
c. Elected and Appointed State and County Officials
Doe also identifies alleged state actor defendants including various state and federal judges,
California Attorney General Rob Bonta, Governor Gavin Newsom, judicial council officials, state
bar representatives, civil rights commission members and “regulatory agency personnel in their
official capacities. R. Doc. 1 at 243-246. 	She also asserts a claim for intentional infliction of
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“constitutional harm. Id. She also seeks injunctive and declaratory relief. Doe states that she seeks
to enjoin them for “ongoing constitutional violations” under §1983, §1985, and §1986.
Under the Eleventh Amendment, “[f]ederal courts are without jurisdiction over suits
against a state, a state agency, or a state official in his official capacity unless that state has waived
its sovereign immunity, or Congress has clearly abrogated it.” Moore v. La. Bd. of Elementary &
Secondary Educ., 743 F.3d 959, 963 (5th Cir. 2014). But under the rule of Ex parte Young, 209
U.S. 123, 28 S. Ct. 441, 52 L. Ed. 714 (1908), “a federal court may enjoin a state official in his
official capacity from taking future actions in furtherance of a state law that offends federal law or
the federal Constitution.” Moore, 743 F.3d at 963.
For a suit against a state official to proceed under Ex parte Young, “three criteria must be
satisfied: (1) A ‘plaintiff must name individual state officials as defendants in their official
capacities’; (2) the plaintiff must ‘allege[ ] an ongoing violation of federal law’; and (3) the relief
sought must be ‘properly characterized as prospective.’ ” Green Valley Special Util. Dist. v. City
of Schertz, 969 F.3d 460, 471 (5th Cir. 2020) (en banc) (citations omitted) (first quoting Raj v. La.
State Univ., 714 F.3d 322, 328 (5th Cir. 2013); and then quoting Verizon Md., Inc. v. Pub. Serv.
Comm'n, 535 U.S. 635, 645, 122 S. Ct. 1753, 152 L.Ed.2d 871 (2002)). When plaintiffs ask for
declaratory and injunctive relief from the alleged “ongoing ... conduct” of an “unconstitutional
restraint” on their rights, the issue is then whether the officials they have sued are proper
defendants. See Book People, Inc. v. Wong, 91 F.4th 318, 334–35 (5th Cir. 2024).
“To be a proper defendant under Ex parte Young, a state official ‘must have some
connection with the enforcement of’ the law being challenged.” Mi Familia Vota v. Ogg, 105 F.4th
313, 325 (5th Cir. 2024) (quoting Ex parte Young, 209 U.S. at 157, 28 S. Ct. 441). “However,
decisions on the subject are not a model of clarity on what constitutes a sufficient connection to
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enforcement. Still, there are ‘guideposts’ to aid the decision.” Id. (citation omitted) (first quoting
Tex. Democratic Party v. Abbott, 961 F.3d 389, 400 n.21 (5th Cir. 2020) [hereinafter Texas
Democratic Party I]; and then quoting Tex. All. for Retired Ams. v. Scott, 28 F.4th 669, 672 (5th
Cir. 2022)). “[T]he state official must have a duty beyond ‘the general duty to see that the laws of
the state are implemented.’ Rather, the official must have ‘the particular duty to enforce the statute
in question and a demonstrated willingness to exercise that duty.’” Book People, 91 F.4th at 335
(footnote omitted) (quoting City of Austin v. Paxton, 943 F.3d 993, 999–1000 (5th Cir. 2019)).
“Plaintiffs need only show a ‘scintilla of enforcement by the relevant state official.” Id.
(quoting Tex. Democratic Party v. Abbott, 978 F.3d 168, 179 (5th Cir. 2020) [hereinafter Texas
Democratic Party II]). “[D]irect enforcement ... is not required.” Air Evac EMS v. Texas
Department of Insurance, 851 F.3d 507, 519 (5th Cir. 2017).
Although not identified initially as parties, Doe complains about the judicial determinations
of Judge Danny Chou, Judge Nico Dorbetas, Judge Cory Gilmore, and Judge Barbara Conway.
For example, she complains about Ontario Judges Gilmore and Conway issuance of an injunction.
R. Doc. 1 at 273, ¶39-41. Regarding Judge Chou, she complains about a decision he rendered on
a motion filed in 2022 which she disagreed with. Id. at 274, ¶48.
Doe also complains about the judicial determination by Orange County Superior Court
Judge Nico Dourbetas where in August 2024 he determined that her case was vexatious and barred
her from initiating a claim in state court without first obtaining permission. R. Doc. 1 at 277, ¶67-
71. She additionally complains that Los Angeles Superior Court Judge Stephanie Bowick from
July to November 2024 refused to grant Doe’s fee waiver on three separate occasions. Id. at 278,
¶80.
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Likewise, she complains about San Mateo Superior Court Judge Nina Shapirsheten’s
denial of Doe’s request for pauper status. Id. at 279, ¶85. Additionally, Doe named the State Bar
of California because she filed multiple bar complaints against the lawyers and judicial complaints
against four state court judges. Id. at 277, ¶73.-74. 	Both the State Bar and Judicial counsel
dismissed her various complaints, and she now identifies them as Defendants in the present suit.
Further, her allegations against Governor Newsom and California Attorney General Rob Bonta are
that she made them aware of over 40 instances of judicial corruption, yet they refused to intervene.
Id. at 277-279, ¶73.-74
In this case, there are no allegations of an ongoing violation of federal law by any specific
state official including Governor Newsom and AG Bonta, or the California State Bar, law
enforcement and judicial council judges. The allegations she set forth fail to set forth how these
defendants violated federal law but instead complains about their failure to act on her complaints
of violations of her rights by others and their denial of her requests to proceed in her state lawsuits.
Therefore, pursuant to the Younger Abstention Doctrine, her claims against Governor Newsom
and AG Bonta, Orange County Superior Court Judge Nico Dourbetas, State Bar and Judicial
Council, Los Angeles Superior Court Judge Stephanie Bowick, and San Mateo Superior Court
Judge Nina Shapirsheten should be dismissed.
d. 	Coerced 	Settlement, 	Breach 	of 	Written 	Contract, 	Fraudulent
Inducement, Trespass to Chattels,
Doe next contends that she was coerced in 2014 to terminate her counsel and accept
representation from Sequoia Capital’s “elite legal team”, Quinn Emanual LLP, Goodwin Procter,
LLP and Wilson Sonsini LLP. R. Doc. 1 at 22. Doe contends that she was coerced into signing a
$40 million settlement agreement drafted by Quinn Emanuel LLP, Goodwin Procter LLP and
Wilson Sonsini at the Rosewood Sand Hill Hotel in California. Id.
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Doe seeks to assert the same claim against Goguen and Sequoia Capital but indicates that
as to the settlement she was coerced. R. Doc. 1 at 97-103. Doe also contends that Sequoia should
be liable because it benefited as a result of her being trafficked. Id.
Doe also alleges that Glaser Weil LLP, Bisnar Chase LLP, Sherman Law, Paoli & Purdy
LLP, Brown Charbonneau LLP, Rivers J. Morrell, III Law Firm, Quinn Emanuel Ruquart &
Sullivan LLP, Goodwin Procter LLP, Wilson Sonsini Goodrich & Rosati LLP, Nemecek & Cole,
Lenczner Slaght LLP and their individual attorneys acting in personal and professional capacities.
Id. at 103-106. She alleges that the defendants undertook contractual, ethical and fiduciary
obligations to act in her best interest but failed to pursue legal relief for her and sabotaged or
undermined her claims. Id. at 104.
Doe claims the $40 million agreement was allegedly executed without independent counsel
or negotiation, and she alleges that as a result Goguen then immediately, “braced the contract”
and forced her to seal the deal. R. Doc. 1 at 22. She claims in another part of the complaint that
she received $10 million from the settlement and is suing for the breach of the “settlement
agreement.” Id. at 25. She complains that she did not have her own counsel and was coerced into
silence via non-disclosure clauses. Id. at 96.
Doe additionally claims that she was injured as a result of the Defendants’ interference
with her personal property such as her devices electronic data, digital files, and accounts. R. Doc.
1 at 147. She asserts this claim is based on New York law. Id. It is unclear where the tort occurred
or how, but it is clear that personal jurisdiction does not exist.
Federal courts are courts of limited jurisdiction. They possess only the power authorized
by the Constitution and statute.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377,
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114 S. Ct. 1673, 128 L.Ed.2d 391 (1994). “It is to be presumed that a cause lies outside this limited
jurisdiction, and the burden of establishing the contrary 	rests upon 	the party asserting
jurisdiction.” Id. Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28, 32, 123 S. Ct. 366, 154
L.Ed.2d 368 (2002) (quoting Great N. Ry. Co. v. Alexander, 246 U.S. 276, 280, 38 S. Ct. 237, 62
L. Ed. 713 (1918)). “If at any time before final judgment it appears that the district court lacks
subject matter jurisdiction, the case shall be remanded.” 28 U.S.C. § 1447(c).
The original claim involves a settlement alleged to have occurred in California between
California residents. 	This court has no jurisdiction in Louisiana over Doe’s breach of the
California settlement claim. There is no federal question and nor is there any diversity of
citizenship present. Additionally, Doe seeks to allege fraudulent inducement and breach of the
written contract both of which are state law claims where there is no diversity nor personal
jurisdiction over the fraudulent inducement, coerced settlement or trespass of chattel’s claims.
For the reasons assigned about these claims are frivolous. It is recommended that the claims
asserting that her California settlement was coerced, that the Defendants breached the contract
and that she was fraudulent Inducement be dismissed for lack of subject matter jurisdiction.
e. 	Conspiracy to Commit Offense or to Defraud, Obstruction of
Justice, Witness Tampering, Victim Retaliation
Doe also claims a violation of 18 U.S.C. § 371, conspiracy to defraud the United States. R.
Doc. 1 at 3. “Conspiracy to commit offense or defraud United States” provides:
If two or more persons conspire either to commit any offense against the United
States, or to defraud the United States, or any agency thereof in any manner or for
any purpose, and one or more of such persons do any act to affect the object of the
conspiracy, each shall be fined under this title or imprisoned not more than five
years, or both.
If, however, the offense, the commission of which is the object of the conspiracy,
is a misdemeanor only, the punishment for such conspiracy shall not exceed the
maximum punishment provided for such misdemeanor.
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18 U.S.C. § 371.
Doe also claims that the defendants conduct constitutes obstruction of justice criminally
and civilly pursuant to Title 18 U.S.C. § 1503. R. Doc. 1 at 76. She seeks damages for the financial
collapse she experienced. Id.
Doe also contends that the defendants conduct constitutes witness tampering. R. Doc. 1
at 248. She does not however provide facts or allegations about any particular witnesses who
testimony was impacted in anyway.
Doe additionally contends that the Defendants conduct constitutes victim retaliation. R.
Doc. 1 at 246-249. 	According to Doe in Count 58, the Defendants sustained an organized
campaign of retaliation against her for reporting that she was trafficked, raped, and the subject of
sexual slavery. Id.
Title 18 U.S.C. § 371 and Title 18 U.S.C. § 1503 are criminal, not civil statutes.
“‘Generally, criminal statutes do not confer private rights of action, and thus any party asserting
a private right bears the burden of establishing its existence.’” Grajeda v. Bank of America, N.A.,
No. 12-CV-1716-IEG (NLS), 2013 WL 2481548, at *2 (S.D. Cal. June 10, 2013) (citation
omitted) and 	Fiorino v. Turner, 476 F. Supp. 962, 963 (D. Mass. 1979) (“With regard to the
alleged violations of 18 U.S.C. §§ 241, 242, 371, and 1001, plaintiff has failed to cite, and the
court has been unable to locate, any authority which would support civil cause of action for
violations of these provisions.”).
To the contrary, case law indicates that violation of §371 and §1503 does not give rise to
a civil cause of action. 	See Cleveland v. Dripping Springs Independent School District, No.
1:19-cv-1256, 2020 WL 10054501, at *2 (W. D. Tex. June 24, 2020); See Bradley v. Abrams,
No. 3:11-cv-238, 2012 WL 1032960, at *3 (D. Conn. March 27, 2012), (holding no private right
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of action under 18 U.S.C. § 1503). Therefore, the Court lacks subject matter jurisdiction over
these proposed claims.
Regarding the claim of witness tampering pursuant to Title 18 U.S.C. § 1512, this statute
is limited to tampering that affects an official federal proceeding or investigation. Doe’s claims
are generalized and seemingly include only state court and foreign court proceedings. As such,
the Court has no jurisdiction over such a claim. Further, Doe has no private cause of action for
the alleged violation of 18 U.S.C. § 1512. See Joynes v. Meconi, Civ. No. 05–332–GMS, 2006
WL 2819762, at *10 (D. Del. Sept. 30, 2006); Baker v. City of Hollywood, Civ. No. 08–60294–
CIV, 2008 WL 2474665, at *9 (S.D. Fla. June 17, 2008); Gipson v. Callahan, 18 F.Supp.2d 662,
668 (W.D.Tex.1997).
As for Doe’s claim of victim retaliation, Doe generally asserts a claim but fails to set forth
facts to support the claim. Even if she could assert such a claim, the Court would lack subject
matter jurisdiction because there is no private right to sue pursuant to Title 18 U.S.C. § 1513.
See Wall v. District of Columbia, No. 23-3342, 2025 WL 958233, at *5 (D. D. C. March 31,
2025).
This Court further does not have jurisdiction under the Racketeer Influenced and Corrupt
Organizations Act (RICO) Claim. The alleged RICO violation arises out of the obstruction of
justice, witness tampering and victim retaliation claims neither of which provided Doe with a
private right of action. R. Doc. 1 at 75. Therefore, because there is no private right of action, the
Court does not have subject matter jurisdiction over Doe’s Obstruction of Justice, Witness
Tampering, Victim Retaliation, and RICO claims and they should be dismissed.
f. 	Violence Against Women Act (VAWA)
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Doe also alleges in Count six of her complaint that Michael Goguen and his corporations
and lawyers violated her civil rights in violation of the Violence Against Women Act (VAWA).
R. Doc. 1 at 53. 	This statute provides a cause of action against a person who commits a crime of
violence motivated by gender.
However, in United States v. Morrison, 529 U.S. 598, 601 (2000), Justice Rehnquist
writing for the Court held that the Commerce Clause did not provide Congress with the authority
to enact a civil remedy provision of VAWA. The Court noted that in as much the provision was
not regulation of activity that substantially affected interstate commerce. Therefore, this Court
lacks subject matter jurisdiction of Doe’s violence Against Women Act claim as it has been
deemed unconstitutional.
3. 	Treaty Violations
Doe also identified several treaties as a basis of recovery, namely, the Palermo Protocol,
Art. 6, International Covenant on Civil and Political Rights, Convention Against Torture, and
Universal Declaration of Human Rights, Art. 3, 5, 7, and 8. R. Doc. 1 at 99. 	Doe also alleges
violations of the Convention on the Elimination of all Forms of Discrimination Against Women.
Id. at 231-234.
a. 	Palermo Protocol
The “Palermo Protocol” is an international agreement that instructs signing States to
establish criminal offences for human trafficking. R. Doc. 1 at 184. Palermo Protocol, November
15, 2000, 2225 U. N .T .S 209. Article 5 “supplements the United Nations Convention Against
Transnational Organized Crime” and “shall be interpreted together with the Convention.”
Palermo Protocol, supra, Art. 1. To that end, this Protocol applies “where those offences are
transnational in nature and involve an organized criminal group.” Id., Art. 4 (emphasis added).
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An “organized criminal group” is defined as “a structured group of three or more persons,
existing for a period of time and acting in concert with the aim of committing one or more serious
crimes or offenses established in accordance with this Convention.” G.A. Res. 55/25, United
Nations Convention Against Transnational Organized Crime, Art. 2(a) (Nov. 15, 2000). 	The
Palermo Protocol identified as harmful—and sought international cooperation to address—a
specific type of conduct: trafficking at the hands of organized criminal groups.
The text of the Palermo Protocol is explicit in declaring that “[n]othing in this Protocol
shall affect the rights, obligations and responsibilities of States and individuals under international
law....” Palermo Protocol art. 14. Because the Palermo Protocol “does not of its own force impose
obligations as a matter of international law,” and it does not condemn the specific conduct
Plaintiff alleges, the Palermo Protocol does not reflect obligations enforceable on our domestic
courts nor binding customary international law. Sosa v. Alvarez, 542 U.S. 692, 734 (2004). Thus,
based on the allegations in the complaint, the Palermo Protocol does not provide a present-day
law-of-nations violation for Plaintiff to state a claim, and it should therefore be dismissed.
b. International Covenant on Civil and Political Rights
Doe also lists the International Convention on Civil and Political Rights as a basis for
recovery. R. Doc. 1 at 184. For the reasons assigned, the International Covenant on Civil and
Political Rights claims should be dismissed.
The International Covenant on Civil and Political Rights (ICCPR) provides, inter alia: a
“[s]entence of death shall not be imposed for crimes committed by persons below eighteen years
of age”. International Covenant on Civil and Political Rights, Dec. 19, 1966, Art. 6, para. 5, S.
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Exec. Doc. E, 95–2, at 23 (1978), 999 U. N. T .S. 171, 175 [hereinafter ICCPR] (emphasis added).
In 1992, the United States Senate ratified the ICCPR with various reservations, understandings,
declarations, and a proviso, stating in pertinent part:
[T]he United States reserves the right, subject to its Constitutional constraints, to
impose capital punishment on any person (other than a pregnant woman) duly
convicted under existing or future laws permitting the imposition of capital
punishment, including such punishment for crimes committed by persons below
eighteen years of age.
[T]he United States declares that the provisions of Articles 1 through 27 of the [ICCPR]
are not self-executing, and thus is not binding as a matter of domestic law. See Dickens v. Lewis,
750 f.2d 1251 (5th Cir. 1984) (where the Court held that the plaintiff lack standing to sue for an
alleged violation of the International Covenant on Civil and Political Rights.); Igartua v. United
States, 654 F.3d 99, 100 (1st Cir. 2011) (citing Igartua-De La Rosa v. United States, 417 F.3d
145, 150 (1st Cir. 2005)). 	Accordingly, this provision has no application to this case. This
provision prohibits the imposition of the death penalty for a person under the age of eighteen
years old. 	Doe’s inclusion of this provision does not either provide jurisdiction or state claim
upon which relief can be granted and therefore it should be dismissed.
c. Convention Against Torture
Doe next claims that the Convention Against Torture provides a basis for recovery. R. Doc.
1 at 99. However, for the reasons assigned below this provision does not provide a basis for
jurisdiction.
The Convention Against Torture and Other Forms of Cruel, Inhuman or Degrading
Treatment or Punishment was adopted by the United Nations General Assembly in 1984 and
entered into force as to the United States in 1994. Cornejo–Barreto v. Seifert, 218 F.3d 1004,
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1007 and n. 1 (9th Cir. 2000) (citing G.A. Res. 39/46, 39 U.N. GAOR Supp. No. 51 at 197, U.N.
Doc. A/RES/39/ 708). Article 3 of the Torture Convention provides as follows:
1. 	No State Party shall expel, return (“refouler”) or extradite a person to another State
where there are substantial grounds for believing that he would be in danger of
being subjected to torture.
2. 	For the purpose of determining whether there are such grounds, the competent
authorities shall consider all relevant considerations including, where applicable,
the existence in the State concerned of a consistent pattern of gross, flagrant or mass
violations of human rights. Cornejo–Barreto, 218 F.3d at 1011.
Article 3 of the Torture Convention was implemented by Congress in 1998 in section 2242
of the FARR Act, which was codified in a note to 8 U.S.C. § 1231, and which provides, in
pertinent part, as follows:
(a) Policy.—It shall be the policy of the United States not to expel, extradite,
or otherwise effect the involuntary return of any person to a country in which there
are substantial grounds for believing the person would be in danger of being
subjected to torture, regardless of whether the person is physically present in the
United States.
(d) Review and construction.—Notwithstanding any other provision of law,
and except as provided in the regulations described in subsection (b), no court shall
have jurisdiction to review the regulations adopted to implement this section, and
nothing in this section [this note] shall be construed as providing any court
jurisdiction to consider or review claims raised under the Convention or this section
[this note], or any other determination made with respect to the application of the
policy set forth in subsection (a), except as part of the review of a final order of
removal pursuant to section 242 of the Immigration and Nationality Act (8 U.S.C.
1252).
The Convention Against Torture therefore does not provide a basis for jurisdiction as
alleged by Doe. Therefore, this proposed claim should be dismissed.
d. 	Canadian Victims Bill of Rights, Canadian Common Law of Unjust
Enrichment, Ontario Human Rights Code and the Canadian
Human Rights Act, conspiracy to defraud the Supreme Court of
Canada and Obstruct Justice.
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Doe in count 47 alleges that the Defendants violated the Canadian Victims Bill of Rights.
R. Doc. 1 at 203-206. While Doe alleges that she is from Canada, she resides in California.
According to her complaint, Canadian judges and U.S. Judges sabotaged her due process. Id. She
also alleges that the Defendants engaged in repeated fraud upon the Court in Ontario. Id. She also
seeks to allege that the Defendants violated the Ontario Human Rights Code and the Canadian
Human Rights Act. Id. at. 214-216.
Doe also contends in Count 50 that Cory Gilmore, Barabara Conway, Quinn Emanuel
Urquhart & Sullivan LLP, Lenczner Slaght LLP, Diane Doolittle, Monique Jilesen, Sahar Talebi,
John Quinn, Kyle Batter and all related legal agents and co-conspirators violated Canadians law
of tort, fraud, and its charter of rights and freedom. Id. at 221. She alleges that these Defendants
orchestrated the use of Ontario courts as a fraudulent collection arm for an unenforceable
California judgment. Id. Additionally, she alleges that these attorneys participated in ex parte
communications with Ontario judges. Id. at 222.
Federal courts are courts of limited jurisdiction, possessing “only that power authorized by
Constitution and statute.” Gunn v. Minton, 568 U.S. 251, 256 (2013) (quoting Kokkonen v.
Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994)). “It is to be presumed that a cause lies
outside this limited jurisdiction, and the burden of establishing the contrary rests upon the party
asserting jurisdiction.” Energy Mgmt. Servs., LLC v. City of Alexandria, 739 F.3d 255, 258-59
(5th Cir. 2014) (quoting Kokkonen, 511 U.S. at 377).
Generally, a federal court has jurisdiction over a case in two circumstances. The first,
known as federal question jurisdiction, exists if a case “arises under the Constitution, treaties or
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laws of the United States.” 28 U.S.C. § 1331. The second circumstance in which a federal court
has jurisdiction is frequently termed diversity jurisdiction. See generally 28 U.S.C. § 1332
(setting out the elements required for jurisdiction based on “diversity of citizenship”).
“Diversity jurisdiction under 28 U.S.C. § 1332 only exists where the parties are citizens of
different states and the amount in controversy exceeds $ 75,000.” White v. FCI USA, Inc., 319
F.3d 672, 674-675 (5th Cir. 2003). If the asserted basis of federal jurisdiction is the diversity of
the parties, 28 U.S.C. § 1332, the party seeking to invoke federal diversity jurisdiction bears the
burden of establishing both that the parties are diverse and that the amount in controversy
exceeds $75,000. Manguno v. Prudential Prop. & Cas. Ins. Co., 276 F.3d 720, 723 (5th Cir.
2002).
Although alienage jurisdiction and diversity jurisdiction are distinct concepts, they are both
governed by 28 U.S.C. § 1332, and they both require complete diversity between the parties.
Panalpina Welttransport GmBH v. Geosource, Inc., 764 F.2d 352, 354–55 (5th Cir. 1985)
(existence of aliens on both sides of a dispute destroys diversity jurisdiction); Stiftung v. Plains
Mktg., L.P., 603 F.3d 295, 297 (5th Cir. 2010); Brown v. Soilmec S.p.A., No. 3:14-CV-1547-D,
2014 WL 2750346, at *2 (N.D. Tex. June 17, 2014) (citing 14A Charles A. Wright, et al., Federal
Practice and Procedure § 3661, at 5 (4th ed. 2013); Vantage Drilling Co. v. Hsin–Chi Su, 741
F.3d 535, 537 (5th Cir. 2014) (per curiam) (“[Section] 1332(a)(2) requires complete diversity.”)).
Doe claims that she is a Canadian Citizen. R. Doc. 1 at 11. She also claims that Lenczner
Slaght LLP and its attorneys are lawyers in Ontario whom she claims participated directly in
fraudulent legal proceedings. Id. at 9. She claims that they were involved in the illegal
enforcement of a Mareva injunction that deprived her of all of her assets, housing and medical
security. Id. Doe’s attempt to invoke this court’s diversity or alienage jurisdiction fails.
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Based on Doe’s complaint, the parties are not entirely diverse because the Plaintiff and
several of the Defendants are Canadian parties on both sides of the case such that this court lacks
authority to hear this case pursuant to federal diversity. Further, the claims based on various
Canadian laws does not present a federal question. Therefore, Doe claims based on Canadian
Victims Bill of Rights, Canadian Common Law of Unjust Enrichment, Ontario Human Rights
Code, the Canadian Human Rights Act, and conspiracy to defraud the Supreme Court of Canada
and Obstruct Justice should be dismissed.
e. 	The Convention on the Elimination of all Forms of Discrimination
Against Women (CEDAW)
In count 53, Doe alleges that the Defendants violated the Convention on the Elimination
of All Forms of Discrimination Against Women. R. Doc. 1 at 231-234. Using the same facts of
judicial sabotage, gag orders and forced representation, Doe contends that the defendants
protected perpetrators who trafficked her. Id. She further contends that the defendants enabled
and 	perpetuated 	her 	captivity 	and 	homelessness, 	and 	prolonged 	traumatization 	across
jurisdictions. Id.
The Convention on the Elimination of All Forms of Discrimination Against Women does
not impose liability on corporations. See generally Convention on the Elimination of All Forms
of Discrimination Against Women, Dec. 18, 1979, 1249 U.N.T.S. 13. The United States is not a
party to the CEDAW, so obligations are directed to State Parties. The lack of duties imposed on
corporations and lack of corporate liability in these treaties indicates that states have not intended
for corporations to be held liable for human rights violations. See Doe v. Exxon Mobil
Corporation, 391 F. Supp. 3d 78 (D. D.C. 2019). Therefore, the Court lacks jurisdiction over
Doe’s claim for violation of the Convention on the Elimination of All Forms of Discrimination
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Against Women fails to state a claim against Sequoia Capital Operations, LLC and Two Bear
Capital are corporations.
Regarding the claim against Michael Lewis Goguen, Diane Doolittle, John Quinn, Bruce
Van Dalsem, Kyle Batter, Anthony McCusker, Patricia Glaser, Jill Basinger, William Paoli,
Brian Chase, Scott Ritsima, Richard Sherman, Monique Jilesen, Sahar Talebi Barbara Conay,
Cory Gilmore, Quinn Emanuel Urquhart & Sullivan LLP,, Goodwin Procter LLP, Wilson
Sonsini Goodrich & Rosati LLP, Glaser Weil LLP, 	Paoli & Purdi LLP, Bismar Chase LLP,
Nemecek & Cole LLP, Rivers J. Morrell III Law Firm, Lenczner Slaght LLP there are no true
factual allegations here because Doe fails to state how each of these individuals and partnerships
participated in trafficking her, raping her, or even forced drugging her. 	The individuals are
actually attorneys who may have represented the corporate defendants, but there are no facts
detailing specific conduct by them that would warrant relief under the CEDAW. These
allegations therefore fail to state a claim, is frivolous, and should be dismissed.
4. 	Frivolous Claims
a. 	Universal Declaration of Human Rights
Doe also seeks relief under the Universal Declaration of Human Rights. R. Doc. 1 at 182.
Universal Declaration of Human Rights fail to state a claim upon which relief may be granted.
The Universal Declaration of Human Rights is not a treaty or international agreement that
imposes legal obligations. See Sosa, 542 U.S. at 734 (“[T]he Declaration does not of its own
force impose obligations as a matter of international law.”). Rather, it is a statement of principles
aimed at providing a common standard for international human rights. Id. at 734-35. Because it
is not enforceable in American courts, Plaintiff's claims alleging violations of the Universal
Declaration of Human Rights should be dismissed.
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b. 	Attack on Federal Court Judges and Their Judgments
Doe alleges that from 2023 to 2025 she filed multiple federal civil rights and trafficking
lawsuits in California, New York, D.C. and Montana. 	She alleges that these actions were
wrongfully dismissed by biased or conflicted judges including Maame Frimpong, Steve Kim,
Laura Taylor Swain, David O. Carter, and Donald Molloy. R. Doc. 1 at 275. Doe complains that
her filings were repeatedly dismissed under inapplicable doctrines such as res judicata despite with
no prior adjudication on the merits. Id.
Specifically, Doe complains about U.S. District Judge Maame Frimpong who dismissed a
complaint Doe filed in March 2023 finding that her complaint was frivolous. R. Doc. 1 at 275,
¶55. Doe complains about Chief Judge Laura Swain of the Southern District of New York’s
decision to transfer her case to the Central District of California. Id. ¶58. Additionally, Doe
complains about District Judge Donald Molloy’s determination in August 2023 where he
determined that her claims were frivolous and dismissed her trafficking claims. Id., ¶60-61.
Doe seeks to hold the judicial officers liable under Title 42 U.S.C. §1983. R. Doc. 1 at 86.
Doe contends that she seeks only to hold the judges liable for injunctive and declaratory relief. Id.
She claims that the various judges orchestrated and enforced a state-sponsored scheme of
obstruction, retaliation and suppression targeting her. Id. She also contends that the judges violated
her right of access to the courts, and she seeks a declaration from this court that all judgments,
orders, designations and rulings are void ab initio. Id. at 86-87.
Judicial immunity is immunity from suit and not just from the ultimate assessment of
damages. Mireles v. Waco, 502 U.S. 9,10 (1991). “It is the judge's actions alone, not intent, that
[courts] must consider.” Malina v. Gonzales, 994 F.2d 1121, 1125 (5th Cir. 1993). Furthermore,
the Federal Courts Improvement Act of 1996 (“FCIA”) prohibits injunctive relief against a
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judicial officer in his or her judicial capacity unless the plaintiff alleges that “a declaratory decree
was violated, or that declaratory relief was unavailable.” Federal Courts Improvement Act of
1996, Pub. L. No. 104-317, § 309(c), 110 Stat. 3847 (1996) (codified as amended in 42 U.S.C. §
1983 (2000)); see also Bolin v. Story, 225 F.3d 1234, 1242 (11th Cir. 2000) (explaining that the
amendment applies to both state and federal judges).
Judicial immunity is only overcome in two sets of circumstances. Mireles, 502 U.S. at 11.
First, a judge is not immune from liability for “non-judicial actions.” Id. To determine whether a
judge's actions are in fact judicial in nature, the court is required to consider four factors: “(1)
whether the precise act complained of is a normal judicial function; (2) whether the acts occurred
in the courtroom or appropriate adjunct spaces such as the judge's chambers; (3) whether the
controversy centered around a case pending before the court; and (4) whether the acts arose
directly out of a visit to the judge in his official capacity.” Ballard v. Wall, 413 F.3d 510, 515 (5th
Cir. 2005). These factors are broadly construed in favor of immunity. Id.
Furthermore, a judge enjoys immunity even if not all of the factors are met. Malina v.
Gonzales, 994 F.2d 1121, 1124 (5th Cir. 1993). The court should examine the “nature and
function” of the act, not the act itself, and whether the act is a general function normally performed
by the judge. Id. Second, a judge is not immune from actions, though judicial in nature, that are
taken in the complete absence of all jurisdiction. Mireles, 502 U.S. at 12.
In this case, Doe complains about the judges in New York, California and Montana’s
decision to dismiss her case. Doe complains about a normal judicial function, and Doe does not
dispute that these judges did not have jurisdiction over her claims. Further, because Doe fails to
allege that a declaratory decree was actually violated or that declaratory relief was unavailable,
any claims for injunctive relief against them are barred by the Federal Courts Improvement Act.
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Therefore, the claims against District Judge Maame Frimpong, District Judge David O Carter and
Magistrate Judge Steve Kim of the Central District of California, District Court Judge Laura
Taylor Swain of the Southern District of New York and District Judge Donald Molloy of the
United States District Court of the District of Montana are dismissed because they are immune,
and the claims against them are frivolous.
c. 	Final Decrees by State Courts
Doe next alleges that her cross-complaints in California were sabotaged when Judges Nico
Dourbetas and Stephanie Bowick dismissed her filings, denied fee waivers and improperly
declared her a vexatious litigant. R. Doc. 1 at 24. Doe alleges that she was denied representation
when she was forced into pro se status for “defaming her trafficker.” Id. Doe contends that these
proceedings were a sham process which denied her due process. Id. 	Notably, she claims this
process occurred even though these courts did not have jurisdiction. Id.
Doe also claims that in 2024 she filed multiple emergency writs with the Supreme Court
of California which were denied by Chief Justice Patricia Guerrero. R. Doc. 1 at 24. The Chief
Justice cited to Doe’s unlawful “vexatious litigant” designation as a barrier to relief in violation
of her due process rights. Id.
Doe also complains about Judge Shapirshteyn’s decision finding Doe guilty of criminal
contempt. R. Doc. 1 at 34. She alleges that the trial occurred in March 2025, that the Court had
no jurisdiction, and that the finding was in error because she was engaged in constitutionally
protected speech. Id.
Doe also seeks to allege in count sixteen that Justice Barbara Conway and Justice Cory
Gilmore in their personal capacity conspired with private parties when they issued and enforced
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Mareva injunctions19 during active California appeals. R. Doc. 1 at 88-89. She further claims that
the justices violated her rights by freezing her trust account and survival assets. Id.
The Rooker-Feldman Doctrine forbids “a party losing in state court ... from seeking what
in substance would be appellate review of the state judgment in a United States district court,
based on the losing party's claim that the state judgment itself violates the loser's federal rights.”
Johnson v. De Grandy, 512 U.S. 997, 1005–06 (1994). The rule is grounded in the recognition
that the subject matter jurisdiction of United States District Courts does not include the authority
to decide appeals from state courts. See 28 U.S.C. § 1257; Exxon Mobil Corp. v. Saudi Basic
Indus. Corp., 544 U.S. 280, 291–92 (2005).
The doctrine derives its name from two Supreme Court cases. In Rooker v. Fidelity Trust
Company, the plaintiffs brought suit in federal court seeking to have an adverse state court
judgment “declared null and void.” 263 U.S. 413, 414 (1923). District of Columbia Court of
Appeals v. Feldman was an action brought against the D.C. Court of Appeals, seeking a
declaration that an opinion of that court violated various constitutional and statutory provisions.
460 U.S. 462, 468 (1983). In both cases, the Supreme Court found that the District Court lacked
subject matter jurisdiction over the actions because the Supreme Court is the only federal court
vested with the authority to review state court decisions. Exxon, 544 U.S. at 283–84.
In 2005, a unanimous Supreme Court set out to clarify the boundaries of the Rooker-
Feldman doctrine. See Exxon, 544 U.S. 280. The Court began by observing that lower courts had
“construed [the doctrine] to extend far beyond the contours of the Rooker and Feldman cases,
19 A Mareva injunction, also known as a freezing order, is a court order that prevents a defendant from dealing with
or dissipating their assets while a legal case is ongoing, ensuring that there are funds available to satisfy a potential
judgment. https://en.wikipedia.org/wiki/Asset_freezing
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overriding Congress’ conferral of federal-court jurisdiction concurrent with jurisdiction exercised
by state courts, and superseding the ordinary application of preclusion law.” Id. at 283. The Court
went on to describe the cases to which the doctrine applies.
The Rooker-Feldman doctrine, we hold today, is confined to cases of the
kind from which the doctrine acquired its name: cases brought by state-court losers
complaining of injuries caused by state-court judgments rendered before the district
court proceedings commenced and inviting district court review and rejection of
those judgments. 	Rooker-Feldman 	does 	not 	otherwise override 	or 	supplant
preclusion doctrine or augment the circumscribed doctrines that allow federal
courts to stay or dismiss proceedings in deference to state-court actions. Id. at 284;
see also Ill. Cent. R. Co. v. Guy, 682 F.3d 381, 390 (5th Cir. 2012).
The holding of Exxon can be broken down into four requirements for application of the
doctrine: (1) the plaintiff lost in state court; (2) the plaintiff complains of injuries caused by a
state-court judgment; (3) the state court judgment was entered before suit was brought in federal
district court; and (4) the plaintiff invites review and rejection of the state court judgment. See
Great Western Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159, 166 (3d Cir. 2010);
Green v. Mattingly, 585 F.3d 97, 101 (2d Cir. 2009). Although the doctrine usually applies only
when a plaintiff attacks the validity of a state court's judgment, the doctrine can also apply if “the
plaintiff's federal claims are so inextricably intertwined with a state judgment that the federal
court is in essence being called upon to review the state court decision.” Ill. Cent. R. Co. v. Guy,
682 F.3d at 391 (internal citations omitted).
Doe challenges the ruling of Orange County Superior Court Judge Nick A. Dourbetas. Doe
also challenges the finding by Lose Angeles County Superior Court Judge Stephanie Bowick.
Doe contends that the rulings of these judges violated her due process rights, and she seeks review
of their determinations.
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Doe also challenges the judicial conduct or decisions of Justices Conway and Gilmore. She
contends that they had no jurisdiction over her, and that the injunction they issued was illegal.
She contends that their judicial decision to freeze her trust accounts was improper and that they
enforced fraudulent judgments.
Doe’s allegations essentially ask this Court to review the state court’s decisions. However,
such relief is barred by the Rooker-Feldman Doctrine. Therefore, Doe’s claims as noted above
should be dismissed.
d. 	Fraud by Goguen, Sequoia, Two Bear, Law Firm, and Lawyers
In Count 9 of the Complaint Doe complains about the conduct of Goguen, Sequoia, Two
Bear Capital, Quinn Emmanuel, LLP, Diane Doolittle, and the individual lawyers of Quin,
Glasser Weil, and Bisnar Chase LLP. R. Doc. 1 at 62. Additionally, she named Sherman Law and
its named partner Richard Sherman, Gregory Brown and his firm Brown & Carbonneau LLP,
Wilson Sonsini of Goodrich & Rosati, Anthony McCluster, and Nemecek & Cole LLP. Id. Doe
also seeks to assert a separate claim of “bad faith” as a part of her claim of fraud by the defendants.
Id. at 153-155.
Doe alleges that there was a fraudulent scheme namely that she was defrauded out of
$40,000,000.00 which was due pursuant to a settlement agreement. R. Doc. 1 at 63. She contends
that the lawyers manufacture fraudulent legal rulings in various jurisdictions. Id. at 62-65. She
complains that the attorneys induced her to abandon her cases, fabricated orders, falsified filings,
submitted perjured testimony in California and Ontario and committed a fraud on the court. Id.
at 67-72. She complains that they allegedly manipulated financial accounts, legal files, and
injunctions. Id. at 63. She complains that they concealed critical documents and orders from her
and denied her the right to participate and defend herself. Id. 	Doe seemingly is indirectly
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challenging the Courts decision that these lawyers were engaged in. She suggests that the court
processes were weaponized against her.
The Fifth Circuit uses a transactional test to determine whether two lawsuits involve the
same claim or cause of action. Test Masters Educ. Servs v. Singh, 428 F.3d at 559, 571 (5th Cir.
2005). Under that test, “a prior judgment's preclusive effect extends to all rights of the plaintiff
with respect to all or any part of the transaction, or series of connected transactions, out of which
the original action arose.” Id. (quoting Petro-Hunt, 365 F.3d at 395–96). In other words, we must
determine whether the claims or causes of action “arise from the same nucleus of operative facts.”
Davis v. Dall. Area Rapid Transit, 383 F.3d 309, 313 (5th Cir. 2004).
Doe’s claims here arise from the same nucleus of operative facts as the claims in her
California lawsuit. Her claims arose out of Goguen conduct and alleged trafficking, the alleged
breach of a settlement and the conduct of the lawyers she retained to represent him. It thus has
preclusive effect. See Fernandez-Montes v. Allied Pilots Ass'n, 987 F.2d 278, 284 n.8 (5th Cir.
1993). Res judicata does not allow Doe to repackage claims founded on the same facts as new
legal theories. See Snow Ingredients, Inc. v. SnoWizard, Inc., 833 F.3d 512, 522 (5th Cir. 2016).
Further to the degree Doe intends to assert a separate claim of bad faith, such a claim is not action
but is a separate element of a fraud claim. 	The fraud claim was previously presented to other
federal courts. Therefore, to the degree Doe seeks to assert fraud and “bad faith”, these claims
should be dismissed for the reasons assigned above.
e. 	Fraud by Goguen, Sequoia, Two Bear, Law Firm, and Lawyers
i. 	Title 42 U.S.C. §1983, § 1981 and Title VI and Title VII
2000d & 2000e.
Doe further contends that the private Defendants Goguen, Sequoia, Two Bear, the Various
Law Firms and lawyers violated her rights under Title 42 U.S.C. § 1983. R. Doc. 1 at 92, 225-
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228. She contends that they allegedly conspired to cause her death by freezing her assets which
prevented her from obtaining medical care, by harassing her in legal actions which resulted in the
exhaustion of her finances. 	Id. at 93. She generally claims that they blocked her court access,
medical appointments and surgery for some unknown medical condition. Id. She also contends
that these Defendants coordinated with judicial actors to deny hearings, seal critical filings and
issue retaliatory rulings knowing that her health was fragile. Id.
Doe contends that she suffered from “chronic life-threatening conditions which require
immediate medical attention.” R. Doc. 1 at 93. She also alleges that the “systematic interference”
of her condition would likely result in medical deterioration and “potential” death. Id.
Doe also contends that Michael Lewis Goguen, Sequoia Capital, Two Bear Capital, Quinn
Emanuel Urquhart & Sullivan LLP, John Quinn, Diane Doolittle, Bruce Van Dalsem, Kyle Batter,
Patricia Glaser, Jill Basinger, Glaser Weil LLP, William Paoli, Paoli & Purdy LLP, Brian Chase,
Scott Ritsema, Bisnar Chase LLP, Richard Sherman, Sherman Law LLP, Gregory Brown, Brown
& Charbonneau LLP, Nemecek & Cole LLP, Monique Jilesen, Lenczner Slagt LLP, Goodwin
Procter LLP, Wilson Sonsini Goodrich & Rosati LLP , the Law Firm of Rivers J. Morrell III and
Alan Brown, Day Day & Brown LLP, and all other named defendants violated Title 42 U.S.C. §
1983, Title U.S.C. §1981, Title VI, and Title VII. R. Doc. 1 at 173-176. Specifically, she claims
that they discriminated against her based on her race as a woman of color and engaged in gender-
based discrimination. Id. at 173.
As to these claims, she contends that the discrimination occurred in the matter in which
they treated her, which was with contempt, hostility and she claimed that she was delusional,
denied her medical care and undermined her credibility with racist and sexist tropes. Id. at. 173.
Doe also alleges that these private Defendants were “functioning as officers of the court” and that
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they abandoned their adversarial roles and coordinated an extrajudicial alliance to deprive her of
due process. Id. at. 226. She alleges that they conspired to secure a judgment against her as a
vexatious litigant, to have her held in contempt in San Mateo and secured a fraudulent judgment
in Los Angeles Court and aligned with federal judges to void and remand her properly removed
case to federal court. Id. at. 227.
“To state a claim under § 1983, a plaintiff must allege the violation of a right secured by
the Constitution and laws of the United States and must show that the alleged deprivation was
committed by a person acting under color of state law.” West v. Atkins, 487 U.S. 42, 48, 108 S.
Ct. 2250, 101 L.Ed.2d 40 (1988). At issue here is the “under color of state law” requirement.
The Supreme Court, has held that “[t]o act ‘under color’ of law does not require that the
accused be an officer of the state.” Adickes v. S.H. Kress & Co., 398 U.S. 144, 152, 90 S. Ct.
1598, 26 L.Ed.2d 142 (1970) (internal quotation marks and citation omitted). Under the Supreme
Court's “public function” test, a private entity acts under color of state law “when that entity
performs a function which is traditionally the exclusive province of the state.” Wong v. Stripling,
881 F.2d 200, 202 (5th Cir.1989).
The Supreme Court has explained that “when private individuals or groups are endowed
by the State with powers or functions governmental in nature, they become agencies or
instrumentalities of the State and subject to its constitutional limitations.” Evans v. Newton, 382
U.S. 296, 299, 86 S. Ct. 486, 15 L.Ed.2d 373 (1966). Thus, the Supreme Court has found private
actors to be susceptible to suit under § 1983. See e.g., West, 487 U.S. at 54–57 (holding that
private doctor under contract with a state prison to provide medical care to prisoners acted under
color of state law when he treated inmate.).
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In this case, the allegations of “medical deprivation” and gender and racial discrimination
fail to state a claim against Goguen, Sequoia Capital, Two Bear Capital, Two Bear Ranch, Quinn
Emanuel Urquhart & Sullivan LLP, Diane Doolittle, John Quinn, Bruce Van Dalsem, Kyle Batter,
Nemecek and Cole LLP, Patricia Glaser, Glaser Weill LLP, Jill Basinger, William Paoli, Paoli &
Purdy LLP, Bisnar Chase, Brian Chase, Scott Ritsima, Richard Sherman, Sherman Law. Neither
of these law firms performed a function which was traditionally in the exclusive province of the
state. Therefore, the medical deprivation claim pursuant to §1983 against Goguen, Sequoia
Capital, Two Bear Capital, Two Bear Ranch, Quinn Emmanuel Urquhart & Sullivan LLP, 	Diane
Doolittle, John Quinn, Bruce Van Dalsem, Kyle Batter, Nemecek and Cole LLP, Patricia Glaser,
Glaser Weill LLP, Jill Basinger, William Paoli, Paoli & Purdy LLP, Bisnar Chase, Brian Chase,
Scott Ritsima, and Richard Sherman of Sherman Law should be dismissed.
As for the 1983 claim, Doe alleges that the private attorneys were “operating as officer of
the court” and that they abandoned their adversarial roles and coordinated an extrajudicial alliance
to deprive her of due process. Id. at. 226. She alleges that they conspired to secure a judgment
against her as a vexatious litigant, to have her held in contempt in San Mateo, secured a fraudulent
judgment in Los Angeles Count, and aligned with federal judges to void and remand her properly
removed case to federal court. Id. at. 227. In essence, what she actually is complaining about is
that the lawyers were successful in obtaining results for their clients who were private citizens.
There is no connexity to the state that would warrant state action as required to bring a Section
1983 claim. Therefore, these claims should be dismissed.
As for Doe’s §1981 claim, it too fails to state a claim. Section 1981 does not provide a
general cause of action for race discrimination. Garrett v. Tandy Corp., 295 F.3d 94, 100 (1st
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Cir.2002); Youngblood v. Hy–Vee Food Stores, Inc., 266 F.3d 851, 855 (8th Cir.2001), cert.
denied, 535 U.S. 1017, 122 S.Ct. 1606, 152 L.Ed.2d 621 (2002); Hampton v. Dillard Dep't Stores,
Inc., 247 F.3d 1091, 1118 (10th Cir.2001). Rather, it prohibits intentional race discrimination with
respect to certain enumerated activities.20
Doe’s complaint fails to state a claim for violation of §1981 because there is no general
cause of action for race discrimination. Rather, the discrimination must result from the loss of an
actual not speculative contract interest. 	In this section, Doe’s allegations do not arise out of a
contract but instead the method of communication that the various attorneys allegedly engage in
disparaging comments about her ethnicity, identity and referring to her as “property, “broken”,
and “mentally unstable”, dangerous, and vexatious. 	She claimed that some of the filings were
retaliatory, mocking in nature and sought to penalize her for conduct routinely tolerated by white
males in litigation. R. Doc. 1 at 174-175. However, these claims fail to state a cause of action
under Title 42 U.S.C. § 1981 and should be dismissed.
Regarding Doe’s attempt to assert a claim pursuant to Title VII, 42 U.S.C. § 2000(d) &
2000(e), 	this 	claim 	also 	fails 	to 	state 	a 	claim 	for 	which 	relief 	may 	be
granted. Title VII, 2000(d) provides that “no person in the United States shall, on the ground of
race, color, or national origin, be excluded from participation in, be denied the benefits of, or be
20 42 U.S.C. § 1981(a) provides that
[a]ll persons within the jurisdiction of the United States shall have the same right in every State and Territory to make
and enforce contracts, to sue, be parties, give evidence, and to the full and equal benefit of all laws and proceedings
for the security of persons and property as is enjoyed by white citizens, and shall be subject to like punishment, pains,
penalties, taxes, licenses, and exactions of every kind, and to no other.
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subjected 	to 	discrimination 	under 	any 	program 	or 	activity 	receiving 	Federal 	Financial
Assistance.” 42 U.S.C. §2000(d).
Further, Title VII also makes it unlawful for an employer to “to fail or refuse to hire or to
discharge any individual, or otherwise to discriminate against any individual with respect to his
compensation, terms, conditions, or privileges of employment, because of such individual's
race....” 42 U.S.C. § 2000e–2(a)(1). Under that framework, an employee establishes a prima facie
case of racial discrimination if he can demonstrate that
she is a member of a protected class, (2) he was qualified for the position at issue, (3) he
was the subject of an adverse employment action, and (4) he was treated less favorably
because of his membership in that protected class than were other similarly situated
employees who were not members of the protected class, under nearly identical
circumstances. Lee v. Kansas City So. Ry., 574 F.3d at 253, 259 (5th Cir. 2009).
In this case, Doe does not allege that she is an employee of any of the above defendants
who treated her less favorably due to a membership in a protected class. Nor does she alleged that
she applied for and was treated unfavorably due to her gender or race under any government
program or in her effort to seek federal financial assistance. It is therefore recommended that the
claims filed pursuant to Title VII 2000(d) & 2000(e) should be dismissed as frivolous.
f. 	Title 42 U.S.C. §1985(3)
Doe also seeks to hold the law firms and their lawyers liable under Title 42 U.S.C. §1985(3)
which forbids two or more persons from conspiring for the purpose of depriving either directly
or indirectly a person equal protection of the laws or cause any act in furtherance of the object of
the conspiracy. R. Doc. 1 at 225. Doe also in Count 59, alleges that the defendants engaged in
continuing violations of a conspiracy. Id. at. 249.
A cause of action under § 1985(3) requires a plaintiff to allege (1) a conspiracy; (2) for the
purpose of depriving a person or class of persons of the equal protection of the laws or equal
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privileges and immunities under the laws; (3) an overt act in furtherance of the conspiracy; and
(4) an injury to the plaintiff's person or property or a deprivation of a right or privilege of a citizen
of the United States. Traggis v. St. Barbara's Greek Orthodox Church, 851 F.2d 584, 586–87 (2d
Cir.1988).
Section 1985(3) creates no substantive rights itself. Rather, it provides a remedy for
violations of the rights it designates, namely, equal protection of the laws and equal privileges
and immunities under the laws. Great American Federal Sav. & Loan Assoc. v. Novotny, 442 U.S.
366, 372, 99 S.Ct. 2345, 2349, 60 L.Ed.2d 957 (1979). Despite its tracking of the language of the
14th Amendment, the Supreme Court has held that § 1985(3) does not by its own terms require
state action for a violation. Griffin v. Breckenridge, 403 U.S. 88, 97, 91 S. Ct. 1790, 1796, 29
L.Ed.2d 338 (1971).
However, the Supreme Court's decision in United Brotherhood of Carpenters & Joiners v.
Scott, 463 U.S. 825, 826, 1013 S. Ct. 3352, 77 L.Ed.2d 1049 (1983) makes clear that a violation
of Section 1985(3) section cannot be alleged absent state action.
Thus, while § 1985(3) applies to private conspiracies if the right being
infringed is protected from private as well as official encroachment, it applies only
to public conspiracies if the right is guarded only from state encroachment. [W]hen
state action is involved, the whole spectrum of rights against state encroachment
that the Constitution sets forth comes into play. When no state action is involved,
only those constitutional rights that exist against private actors may be challenged
under the section. Peavey v. Polytechnic Institute of New York, 775 F. Supp. 75, 76-
78 (E .D .N.Y. 1991).
Plaintiff asserts that the law firms and lawyer Defendants have conspired on account of
gender to deprive her medical treatment and equal protection of the laws under the 14th
Amendment. However, it has always been held that the 14th Amendment guards these rights only
from infringement by state actors. See United States v. Guest, 383 U.S. 745, 755, 86 S. Ct. 1170,
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1176, 16 L.Ed.2d 239 (1966); United States v. Cruikshank, 92 U.S. 542, 554–55, 23 L. Ed. 588
(1876).
Notwithstanding, Doe’s claims can be construed not simply as violating her right to the
equal protection of the laws, but to her right of access to the courts. The right of access to the
courts is one of the fundamental rights protected by the Constitution, “conservative of all other
rights, and lies at the foundation of orderly government.” Chambers v. Baltimore & O.R. Co., 207
U.S. 142, 148, 28 S. Ct. 34, 35, 52 L. Ed. 143 (1907).
In an analysis of the constitutional foundations of the right of access to the courts, the Fifth
Circuit Court of Appeals identified three provisions in the Constitution where courts have found
that right: (1) the privileges and immunities accorded citizens under article 4 and the Fourteenth
Amendment, see id..; (2) the First Amendment, in the right to petition the government, see
California Motor Transport Co. v. Trucking Unlimited, 404 U.S. 508, 92 S. Ct. 609, 30 L.Ed.2d
642 (1972); and (3) the due process clause of the Fourteenth Amendment, see Wolff v. McDonnell,
418 U.S. 539, 94 S .Ct. 2963, 41 L.Ed.2d 935 (1974). Ryland v. Shapiro, 708 F.2d 967, 971 (5th
Cir.1983). In each case, the right is derived from constitutional protections against state
encroachment only. See United Brotherhood of Carpenters & Joiners v. Scott, 463 U.S. at 831–
33, 103 S. Ct. at 3357–59 (1983) (stating that the First Amendment restrains only official
conduct); Guest, supra. Thus, the Fifth Circuit concluded that “the right of access to the courts is
guaranteed and protected from unlawful interference and deprivations by the state.” Guest, 383
U.S. at 755 (emphasis added).
Therefore, a purely private conspiracy to deprive a person of that right cannot violate §
1985(3). The Court finds that the medical deprivation claim pursuant to §1985(3), the First and
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Fourteenth Amendments against Goguen, Sequoia Capital, Two Bear Capital, Two Bear Ranch,
Quinn Emanuel Urquhart & Sullivan LLP, Diane Doolittle, John Quinn, Bruce Van Dalsem,
Kyle Batter, Nemecek and Cole LLP, Patricia Glaser, Glaser Weill LLP, Jill Basinger, William
Paoli, Paoli & Purdy LLP, Bisnar Chase, Brian Chase, Scott Ritsima, Richard Sherman, Sherman
Law should be dismissed as frivolous.
Regarding Count 59, the continuing violations doctrine/ongoing conspiracy claim filed by
Doe, she reasserts the same allegations that the Defendants acted individually and in concert to
perpetuate a systemic and transnational enterprise through trafficking, rape, and torture. 	She
complains about her coerced settlement agreement and the unlawful freezes and seizure of her
property. As indicated earlier, Section 1985(3) creates no substantive rights itself. Therefore,
Doe’s claim of continuing conspiracy should be dismissed as frivolous.21
g. 	Title 42 U.S.C. § 12132
Doe also seeks to assert a medical deprivation claim against the lawyers and law firm
Defendants pursuant to Title 42 U.S.C. § 12132, the American with Disabilities Act, for
purportedly denying her access to medical care and legal processes. R. Doc. 1 at 92.
The ADA is a “broad mandate” of “comprehensive character” and “sweeping purpose”
intended “to eliminate discrimination against disabled individuals, and to integrate them into the
economic and social mainstream of American life.” 42 U.S.C. § 12101(b)(1)-(2). Specifically,
Title II, 42 U.S.C. § 12132, provides that “no qualified individual with a disability shall, by reason
of such disability, be excluded from participation in or be denied the benefits of the services,
21 The other statutory framework mentioned by Doe as a jurisdictional basis have previously been addressed in earlier
portions of this opinion and do not form a basis for jurisdiction; namely- the Trafficking Victims Protection
Reauthorization Act, Racketeer Influenced and Corrupt Organization Act, Alien Tort Act, Title 42 U.S.C. §1983,
§1985, Federal Common Law Conspiracy and Canadian and International human rights law.
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programs, or activities of a public entity, or be subjected to discrimination by any such entity.”
Frame v. City of Arlington, 657 F.3d 215, 223 (5th Cir. 2011).
First, under the ADA/RA there is no private right of action that allows Doe to sue individual
Defendants for money damages. The substantive standards for claims under the ADA and the
Rehabilitation Act are the same. Furgess v. Pennsylvania Department of Corrections, 933 F.3d
285, 288 (3d Cir. 2019). Actions against “public entities” do not allow for liability either against
individual persons or against private corporations contracting to provide healthcare with those
public entities. Matthews v. Pennsylvania Department of Corrections, 613 Fed. Appx. 163, 169–
70 (3d Cir. 2015) (dismissing all ADA and RA claims except against the DOC). See 42 U.S.C.§
12132 (“Subject to the provisions of this subchapter, no qualified individual with a disability
shall, by reason of such disability, be excluded from participation in or be denied the benefits of
the services, programs, or activities of a public entity, or be subjected to discrimination by any
such entity.”) (emphasis added)); 42 U.S.C.§ 12131 (a “public entity” is (a) any State or local
government; (b) any department, agency, special purpose district, or other instrumentality of a
State or States or local government; and (c) the National Railroad Passenger Corporation, and any
other commuter authority). 	Therefore, Doe’s attempt to assert a claim for medical deprivation
against Goguen, Sequoia Capital, Two Bear Capital, Two Bear Ranch, Quinn Emanuel Urquhart
& Sullivan LLP, Diane Doolittle, John Quinn, Bruce Van Dalsem, Kyle Batter, Nemecek and
Cole LLP, Patricia Glaser, Glaser Weill LLP, Jill Basinger, William Paoli, Paoli & Purdy LLP,
Bisnar Chase, Brian Chase, Scott Ritsima, Richard Sherman, Sherman Law for the violation of
Title 42 U.S.C. § 12132 should be dismissed as frivolous.
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h. 	Title 28 U.S.C. §1350
Doe next seeks to sue pursuant to 28 U.S.C. §1350 which is a statute that provides only a
basis for origination of actions filed by aliens. It does not create an independent basis for a claim
but provides the jurisdictional basis of a claim filed pursuant to another federal statute.
Having determined that Doe’s claims filed pursuant to Title 42 U.S.C. §1983, Title 42 U.S.
C. §1985(3), 28 U.S.C. Title 28 U.S.C. §1350 and Title 42 U.S. C. §12132 were frivolous, no
other statute was referenced for a substantive basis for her medical deprivation claim.
i. 	First, Fifth and Fourteenth Amendment Claims
Doe next alleges claims pursuant to the First, Fifth and Fourteenth Amendments. In this
instance alleges that Michael Goguen engaged in retaliatory gag orders or surveillance and
conspired two freeze her assets. R. Doc. 1 at 178. She alleges that Quinn Emanuel and its attorneys
participated in ex parte communication to suppress her speech and colluded with judges to prevent
her access to courts. 	Id. 	She also claims that Sequoia Capital funded litigation campaigns that
involved unlawful ex parte order, seizure of property, and interference with her first and fifth
Amendment Rights. Id. at 177-181.
The First Amendment provides that “Congress shall make no law ... abridging the freedom
of speech.” U.S. Const. amend. I. Within its scope, the First Amendment provides robust protection
for free speech. But it has an important limitation: It “prohibits only governmental abridgment of
speech” and “does not prohibit private abridgment of speech.” Manhattan Cmty. Access Corp. v.
Halleck, 587 U.S. 802, 808, 139 S. Ct. 1921, 204 L.Ed.2d 405 (2019); see Prager Univ. v. Google
LLC, 951 F.3d 991, 996 (9th Cir. 2020).
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“By enforcing [the] constitutional boundary between the governmental and the private, the
state-action doctrine” developed by the Supreme Court to distinguish government from private
action “protects a robust sphere of individual liberty.” Halleck, 587 U.S. at 808, 139 S. Ct. 1921;
accord Lugar v. Edmondson Oil Co., 457 U.S. 922, 936, 102 S. Ct. 2744, 73 L.Ed.2d 482 (1982)
(“Careful adherence to the ‘state action’ requirement preserves an area of individual freedom by
limiting the reach of federal law and federal judicial power.”). The Fifth Amendment Due Process
Clause applies only to the federal government (and state governments, through the Fourteenth
Amendment), and not to private parties. See, e.g., Public Utilities Commission v. Pollak, 343 U.S.
451 (1972).
The claims filed by Doe alleging violations of the First, Fifth and Fourteenth Amendments
are frivolous because these rights require state action, and no state action was alleged in the
complaint. Simply including “Judges, Court Clerks and State Officials” without more is
insufficient to state a claim. Further the Court has considered in a different section of this opinion
the claims against the judges and decided that they are immune from suit. Therefore, the First,
Fifth and Fourteenth Amendment claims against Michael Lewis Goguen, Quinn Emanuel,
Sequoia Capital & Two Bear Capital, Patricia Glaser & Glaser Weil and E. Paoli & Purdy, Bisnar
Chase LLP, Sherman law, Brown & Charbonneau LLP, Nemecek & Cole LLP and the “ judges
and Court Clerks and State Officials should be dismissed.
j. 	The Laws of Nations and Customary International Law Crimes
Against Humanity
Doe is seeking to hold the defendants liable for either engaging in or aiding her being
trafficked. She asserts this claim pursuant to other statutes such as the Alien Tort Statute,
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Enslavement pursuant to Rome law, persecution, Torture Rape and Other inhumane acts. R. Doc.
1 at 186-189. However, Doe’s attempt at asserting claim in these respects also fail.
No national court [outside of the United States] and no international judicial tribunal has
so far recognized corporate liability, as opposed to individual liability, in a civil or criminal
context on the basis of a violation of the law of nations or customary international law. See Kiobel
v. Royal Dutch Petroleum Co., 621 F. 3d 111, (2nd Cir. 2010). Accordingly, insofar as plaintiff in
this action seek to hold only corporations liable and there is no legal support for holding limited
liability partnerships responsible for their conduct in in another country (as opposed to individuals
within those corporations), their claims must be dismissed for lack of subject matter jurisdiction.
Therefore, the claims against Sequoia Capital, Two Bear Capital, Quinn Emanuel Urquhart &
Sullivan LLP, Goodwin Procter LLP, Wilson Sonsini Goodrich & Rosati LLP, Glaser Weil LLP,
Bisnar Chase LLP, Sherman La LLP, Paoli & Purdy LLP should be dismissed.
As for the individually named defendants and the limited liability partnerships, the ATS
created no causes of action but is purely jurisdictional. Under these facts there are no allegations
of sex trafficking in another nation that could provide a basis of jurisdiction and or are the
individual defendants allegedly connected to another country. See Cardona v. Chiquita Brands
Intern., Inc. 760 F.3d 1185, (11th Cir. 2014). Doe’s claims of Crimes against Humanity under
International 	Law 	are 	therefore 	frivolous 	and 	should 	be 	dismissed 	against 	these
Defendants.Venue
a. 	Claims pursuant to 18 U.S.C. §§ 2421, 2422, 2423
Doe identifies various federal criminal statutes as a basis of her personal claims. R. Doc.
1 at 50. Doe alleges that the “defendants violated Title 18 U.S.C. § 2421(Interstate transportation
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for illicit sexual purposes; Title 18 U.S.C. § 2422 (Coercion and enticement); and Title U.S.C.
§2423 (Transportation for illegal sexual activity). Id.
The presence of a criminal statute neither creates nor implies a corresponding private right
of action. Kunzer v. Magill, 667 F.Supp.2d 1058, 1061 (D. Minn. 2009) (citing United States v.
Wadena, 152 F.3d 831, 845–46 (8th Cir.1998)); see Cent. Bank of Denver, N.A. v. First Interstate
Bank of Denver, N.A., 511 U.S. 164, 190–91, 114 S. Ct. 1439, 128 L.Ed.2d 119 (1994); Frison v.
Zebro, 339 F.3d 994, 999–1000 (8th Cir.2003. Private citizens generally have no standing to
institute federal criminal proceedings. Kunzer, 667 F.Supp.2d at 1061 (collecting cases).
However, where a person suffered a violation or personal injury while the person was a
minor, the person may sue in an appropriate District Court for actual damages only for violations
of Title 18 U.S.C. §2421, §2422, §2423. See also Title 18 U.S.C.A. §2255. These statutes do not
place a time limit for the filing but indicates that the action may be brought where the defendant
resides, a substantial part of the events or omission giving rise to the claim occurred, or any judicial
district which a defendant is subject to the court’s personal jurisdiction. 28 U.S.C. § 1391.
Many of the Defendants sued in this case are located in California. Likewise, a substantial
part of the events or omissions are alleged to have occurred in either California or New York but
not Louisiana. Finally, there is no named defendant in Louisiana which could render this Court
proper. Therefore, these claims should be dismissed without prejudice to the extent they have not
been raised in the Northern District of California.
b. 	Peonage, Slavery, Involuntary Servitude- Title 18 U.SC. 1581.
Doe alleges that she was subjected to peonage, enticed him into slavery, subjected to
involuntary servitude, and coerced into forced labor in violation of 18 U.S.C. §§ 1581, 1583, 1584,
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and 1589. Doe further alleges that Sequoia Capital Operations, Goguen, Two Bear Capital, Quinn
Emanuel LLP, Diane Doolittle, John Quinn, Goodwin Procter LLP, Wilson Sonsini Goodrich LLP
and Glaser Weil LLP benefitted financially from peonage, slavery, and trafficking in persons in
violation of § 1593A. R. Doc. 1 at 56-57. Although these provisions are criminal statutes, § 1595
authorizes victims to bring civil actions to recover damages and attorneys’ fees. Gonzalez v.
CoreCivic, Inc., 986 F.3d 536, 537 (5th Cir. 2021).
Sections 1581, 1583, 1584, and 1589 and cases interpreting them make clear that the
conduct they prohibit all involves some element of coercion or compulsion. Peonage, which is
proscribed by § 1581, is defined as “a status or condition of compulsory service or involuntary
servitude based upon a real or alleged indebtedness.” Pierce v. United States, 146 F.2d 84, 86 (5th
Cir. 1944) (citing Bailey v. Alabama, 219 U.S. 219 (1911); Clyatt v. United States, 197 U.S. 207
(1905); United States v. Clement, D.C., 171 F. 974 (1909)).
In the context of a criminal prosecution for peonage, “[i]t is sufficient to allege and prove
that a person is held against his will and made to work to pay a debt.” Id. (citing Bernal v. United
States, 241 F. 339 (5th Cir. 1917); Taylor v. Georgia, 315 U.S. 25 (1942); United States v. Gaskin,
320 U.S. 527 (1944)). For the purposes of § 1983, slavery is generally defined as a condition in
which a person “is wholly subject to the will of another,” deprived of freedom of action, and forced
into “a state of compulsory service to another.” United States v. Booker, 655 F.3d 562, 566 (4th
Cir. 1981). Interpreting § 1584, the Supreme Court held that “the term ‘involuntary servitude’
necessarily means a condition of servitude in which the victim is forced to work for the defendant
by use or threat of physical restraint or physical injury, or by the use or threat of coercion through
law or legal process.” United States v. Kozminski, 487 U.S. 931, 952 (1988). Similarly, the term
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forced labor in § 1589 refers to labor that is obtained through coercion, including “by means of the
abuse or threatened abuse of law or legal process.” 18 U.S.C. § 1589(a).
In this case, Doe contends that she was targeted over a sustained period of years and
coerced that resulted in her being trafficked and subjected to false imprisonment. 	She claims that
the trafficking was coordinated with law firms and private security to enforce her obedience. The
alleged trafficking and the Defendant law firms, and Mr. Goguen and his Sequoia Operations are
located in the Western District of California. The allegations although vague as to the involvement
of each defendant, what is clear is that the Eastern District of Louisiana is not a proper venue, and
the Peonage, Slavery and Involuntary Servitude claims should be dismissed without prejudice to
tallow for them to be brought in the Western District of California.
c. 	Supplemental Jurisdiction
Doe seeks to assert state law claims of trespass to chattels, conversion, money had and
received based on fraud, 	tortious interference with economic relations, intentional interference
with economic relations, defamation, invasion of privacy, abuse of process, and 	unjust
enrichment. 	R. Doc. 1 at 147-153,157-170, 190-194, 210-213, 217, 229-231. These claims are
based on New York tort law.
The name Defendants as to these claims are Michael Lewis Goguen, Sequoia Capital, Two
Bear Capital, Two Bear Ranch, Quinn Emanuel Urquhart Z& Sullivan LLP, Glaser Weil LLP,
Bisnar Chase LLP, Sherman Law LLP, Nemecek & Cole LLP, Paoli & Purdy LLP, Brown &
Charbonneau LLP and “all individually named co-defendants.” Regarding the abuse of process
claim, in addition to the aforementioned defendants, Doe assert this claim against Scott Ritsima,
Richard Sherman, Gregory G. Brown, Goodwin Procter LLP, Anthony McCusker, Wilson Sonsini
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Goodrich & Rosait LLP, Monique Jilesen, Sahar Talebi, Lenczner Slaght LLP, Barbara Conway,
Cory Gilmore for their alleged misuse of the judicial system. R. Doc. 1 at 229. Doe claims that
each of the defendants “suppressed her lawful pursuit of justice and silenced her speech and sought
to seal orders denying her due process of law. Id. Like the other state law claims, Doe relies on
New York law for this claim which provides no basis for this court to address.
As for the defamation claim, it is asserted against Vox Media, the New York Post, Quinn
Emanuel Urquhart & Sullivan LLP, Michael Lewis Goguen, Diane Doolittle, John Quinn Bruce
Van Dalsem, Kyle Batter, Nemecek & Cole LLP, Patricia Glaser, Glaser Weil LLP, Jill Basinger.
These claims allegedly involve the dissemination of defamatory words about her without
verification including such statements that she attempted to extort Goguen, that she is a criminal
and 	that she brought a fraudulent claim, is untrustworthy and lacks credibility. R. Doc. 1 at 191.
As for her invasion of privacy claim, she alleges that the defendants22 hired a private
security firm and intelligence contractors Christopher Reynolds, the Estate of David Fecheimer
and Sitrick- affiliated contractors to intimidate and surveil her. R. Doc. 1 at 195. This claim is also
asserted based on New York law.
Doe additionally cites to several state laws in Louisiana including torts, concealment,
personal injury, defamation, invasion of privacy and also several Louisiana criminal statutes. R.
Doc. 1 at 15. First, none of the claims arise out of any conduct here in Louisiana. Where the Court
22 Michael Lewis Goguen, sequoia Capital, Two Bear Capital, Two Bear Ranch, Quinn Emanuel Urquhart & Sullivan
LLP, Diane Doolittle, John Quinn, Bruce Van Dalsem, Kyle Batter, Patricia Glaser, Glaser Weil LLP, Jill Basinger,
Rivers Morrell, Gregory Brown, William Paoli, Paoli Purdy LLP, Bisnar Chase LLP, Brian Chase, Scott Ritsima,
Richard Sherman, Sherman La LLP, Nemecek & Cole LLP, Michael Strickland Sitrick & Company, Christopher
Reynolds, Estate of David Fecheimer and all individual named and co-conspiring defendants.
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dismisses a federal claim that served as a basis of original jurisdiction, the court retains statutory
supplemental jurisdiction over the state law claims.
Doe further asserts a claim against Michael Goguen, Sequoia Capital, Two Bear Capital,
Two Bear Ranch, Christopher Reynolds, Estate of David Fechheimer, Diane Doolittle, Bruce Van
Dalsem, Kyle Batter, John Quinn, Quinn Emanuel Urqhart & Sullivan LLP for stalking. R. Doc.
1 at 198-201. The stalking according to Doe involved the deployment of intelligence contractors,
tracking of her IP addresses and phone location and unauthorized interception of her legal filings.
Id. at 200. She complains of receiving harassing and threatening emails, texts and calls and
anonymous death threats. Id.
If a district court has original jurisdiction over at least one claim in a case, it must look to
what was traditionally known as “pendent” or “ancillary” jurisdiction to assess whether it has
jurisdiction over any remaining claims over which it would otherwise lack original jurisdiction.
See, e.g., City of Chi. v. Int'l Coll. of Surgeons, 522 U.S. 156, 164–65, 118 S. Ct. 523, 139 L.Ed.2d
525 (1997) (federal question context). Congress has codified the concepts of pendent and ancillary
jurisdiction in the supplemental jurisdiction statute. Id. at 165, (“Congress has codified those
principles in the supplemental jurisdiction statute, which combines the doctrines of pendent and
ancillary jurisdiction under a common heading. 28 U.S.C. § 1367.”); Walter Fuller Aircraft Sales,
Inc. v. Republic of Phil., 965 F.2d 1375, 1389 n. 13 (5th Cir.1992).
The Court does not have original jurisdiction, however, over the claims that arise under
state law. Stay-N-Play Discovery School v. Alverez, et al., No. 06-2979, 2006 WL 2947878, at
*2 (E. D. La. Oct. 14, 2006) (Duval, J.). Yet, if there is factual connexity between the state law
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claims and the federal claims, the Court can employ its supplemental jurisdiction over the state
causes of action. Id. Supplemental jurisdiction is granted pursuant to 28 U.S.C. § 1367, which
provides “that the district courts shall have supplemental jurisdiction over all other claims that
are so related to claims in the action that they form part of the same case or controversy.”
The Court does not have original jurisdiction over the claims raised by Doe as analyzed
earlier in this opinion. The Court consequently does not have supplemental jurisdiction over these
state causes of actions including abuse of process, 	that the defendants suppressed her lawful
pursuit of justice and silenced her speech and sought to seal orders denying her due process of
law, defamation, invasion of privacy, torts, concealment, personal injury, defamation, invasion of
privacy under Louisiana Law, stalking are frivolous and should be dismissed.
It is further recommended that the state court claims of trespass to chattels, conversion,
money had and received based on fraud, tortious interference with economic relations, intentional
interference with economic relations against these claims are Michael Lewis Goguen, Sequoia
Capital, Two Bear Capital, Two Bear Ranch, Quinn Emanuel Urquhart Z& Sullivan LLP, Glaser
Weil LLP, Bisnar Chase LLP, Sherman Law LLP, Nemecek & Cole LLP, Paoli & Purdy LLP,
Brown & Charbonneau LLP and “all individually named co-defendants” should be dismissed.
d. 	Media Entities
In the party identification section of the complaint, Doe names the New York Post, Fox
Corporation, Fox News, Rupert Murdock Bloomberg L.P., NBCUniversal, and MSNBC as
Defendants. R. doc. 1. P. 10. The only allegation against these defendants is that they participated
in coordinated defamation, psychological warfare, 	and reputation sabotage by publishing
propaganda that smeared Doe. 	Id. at. R. doc. 1, ¶15.The alleged published propaganda was done
so as to silence her as a whistleblower and destroy her credibility. Id.
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Defamation is a state law claim. 	It is unclear what state law forms the basis for the
jurisdiction of this court. 	Nevertheless, even if it is New York law, the court does not have
supplemental jurisdiction over these claims against New York Post, Fox Corporation, Fox News,
Rupert Murdock Bloomberg L.P., NBCUniversal, and MSNBC because also lack original
jurisdiction over any of Doe’s claims and the claims against these entities should be dismissed.
IV. 	Recommendation
For these reasons detailed above,
IT IS THEREFORE RECOMMENDED Plaintiff’s Amber Doe’s COMPLAINT 	be
DISMISSED WITH PREJUDICE IN PART and DISMISSED WITHOUT PREJUDICE IN
PART as follows:
IT IS RECOMMENDED THAT ALL CLAIMS IN COUNTS 1-4, 6, 8-62 should be
DISMISSED WITH PREJUDICE.
IT IS ALSO RECOMMENDED THAT AS TO THE CLAIMS IN COUNT 5 OF Title
18 U.S.C. § 2421(Interstate transportation for illicit sexual purposes; Title 18 U.S.C. § 2422
(Coercion and enticement); and Title U.S.C. §2423 (Transportation for illegal sexual activity)
WITHOUT PREJUDICE to being filed in the correct venue.
BOTH 	DISMISSALS 	ARE 	AGAINST 	ALL 	DEFENDANTS 	IDENTIFIED
BELOW;
Defendants Michael Goguen, Sequoia Capital Operations, LLC, Sequoia Capital Franchise
Partners, Sequoia Capital IX, Sequoia Entrepreneurs Annex Fund, Sequoia Heritage, LLC,
Sequoia Capital Growth III Principals Fund, LLC, Sequoia Capital Franchise Fund, LP, Sequoia
Capital Growth Partners, III, LP, Sequoia Capital Global Equities LLC, Sequoia Capital India
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LLP, Sequoia Capital China Fund, LP, Sequoia Capital Canada LLP, Sequoia Capital Israel LLP,
Sequoia Capital Consultants, Inc., Sequoia Capital Wealth Partners, Wilson Sonsini;
1. 	Two Bear Capital and its affiliates including Two Bear Capital Operations LLC, Two Bear
Ranch, Two Bear Farm, Two Bear Air Rescue Foundation, Two Bear Air 1, LLC, Two
Bear Security LLC, Crystal Slopeside LLC, Valley Oak LLC, Whitefish Frontiers LLC,
Proof Research Inc., and the Michael L. Goguen Trust;
2. 	Quinn Emanuel Urquhart & Sullivan LLP and its attorneys including John B. Quinn,
Kathleen Sullivan, Diane Doolittle, Bruce Van Dalsem, Kyle Batter, Michael F. Grady,
Christopher Tayback, William C. Rice, Mark Holsher, Suong Nguyen, Joseph C. Sarles,
Patrick Doolittle, Margaret Caruso, Michael Lifrak, Megan M. Kerr, Sara Cork, Sara
Pollack, Alex Gerbi, Ted Greeno, Aidan O’Rourke, Gregory Pantlin Harry Olivar, and
Alex Spiro;
3. 	Glaser Weil LLP and Patricia Glaser and Jill Basinger;
4. 	Goodwin Proctor LLP and Anthony McCusker, Wilson Sonsini Goodrich and Rosati LLP,
Keith Eggleton;
5. 	Kirkland & Ellis LLP, David Klein, Baker Marquart LLP/Waymaker LLP , Ryan Baker,
Christopher Reynolds, Lenczner Slaght LLP Monique Jilesen, Sahar Talebi, Paoli &
Purdy, LLP, William Paoli, Court Purdy, Binsar Chase, Scott Ritsima, Brown &
Charbonneau LLP, Gregory Brown, Sherman Law and Richard Sherman;
6. 	The Law Offices of Rivers J. Morrell III, Rivers, J. MorrellIII, Day & Day & Brown, Alan
Brown, Nemecek & Cole LLP, Frank W. Nemecek, Jonathan B. Cole, Marshall R. Cole,
Michael W. Feenberg, Michael McCarthy, Mark Schaeffer, Claudia Stone and Marta
Alcumbrac and HerbFox Law Offices;
7. 	Marriott International, Inc., Sheraton Gateway Toronto, Rosewood Hotels & Resorts
LLCC;
8. 	Attorney General Rob Bonta, Governor Gavin Newsom, California Judicial Council
Officials, 	“State 	Bar 	Representatives”, 	“Civil 	Rights 	Commission 	Members”, 	“
Regulatory Agency Personnel”;
9. 	New York Post, Vox Media, Fox Corporation, Fox News, Rupert Murdoch 	Bloomberg
LP, NBCUniversal and MSNBC;
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10. John Does 1-100 unidentified corporate shells, facilitators, traffickers, attorneys and
operatives;
11. Judge Barbara Conway (Canadian Judge) , Judge Cory Gilmore (Canadian Judge), Judge
Danny Chou, Chief Judge Laura Swain Judge Elizabeth Lee, 	Judge Susan Greenberg,
Judge Nina Shapirshteyn, Former Judge Read Ambler, Judge Gransaert, Judge Barbara
Conway, Judge Nico Dourbetas, Judge Maame Frimpong, , Judge Donald Malloy, Judge
Steve Kim, Judge David O Carter; Judge Donald Molloy, Judge Stephanie Bowick, and
“Judges of the Ninth Circuit who declined to review appeal”.
A party’s failure to file written objections to the proposed findings, conclusions, and
recommendation in a magistrate judge’s report and recommendation within fourteen (14) days
after being served with a copy shall bar that party, except upon grounds of plain error, from
attacking on appeal the unobjected-to proposed factual findings and legal conclusions accepted by
the district court, provided that the party has been served with notice that such consequences will
result from a failure to object. Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415, 1430 (5th Cir.
1996).10
New Orleans, Louisiana, this 24th day of November 2025.
____________________________________
KAREN WELLS ROBY
UNITED STATES MAGISTRATE JUDGE
10Douglass referenced the previously applicable fourteen-day period for the filing of objections. Effective
December 1, 2009, 28 U.S.C. § 636(b)(1) was amended to extend the period to fourteen days.
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