State Court Complaint Howard Rubin

(FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM BDEE Boe codtse/ 2028) NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 08/06/2018 SUPREME COURT OF THE STATE OF NEW YORK, NEW YORK COUNTY JULIE PARKER, AMENDED COMPLAINT Plaintiff, Hon. Doris Ling-Cohan Index No. 0650126/2018 ~ against - HOWARD RUBIN, Defendants. X Plaintiff Julie Parker (“Plaintiff” or “Ms. Parker”), by her attorneys, The Landau Group, PC, as and for her Amended Complaint, against Defendant Howard Rubin (“Rubin” or “Defendant”), alleges, as follows PRI iMINARY, 1. The instant case involves a brutal rape, and gruesome acts of sexual abuse, committed by Defendant Howard Rubin, against Plaintiff Julie Parker, PARTIES, JURISDICTION AND VENUE 2. Plaintiff Julie Parker is an individual residing in Los Angeles, California, 3. Defendant Howard Rubin is a resident of New York, New York, and was one of the top Portfolio Managers at Soros Fund Management, LLC, located in New York, New York. 4, A substantial part of the events giving rise to Plaintiff's claim occurred in the County of New York. 5, Venue is therefore proper in this Court pursuant to CPLR 503(a). 6. This Court has jurisdiction pursuant to CPLR 301. STATEMENT OF FACTS 1 of 19(FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM BDEE Boe codtse/ 2028) NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 08/06/2018 7. On or before November 3, 2015, Plaintiff was introduced to a person named Nicole Minton (“Minton”), while she was visiting New York City, 8. Plaintiff and Minton exchanged text messages, and Plaintiff told Minton about herself, and sent her photos 9. During this correspondence, Minton informed Plaintiff that she would be paid $2,000.00 to go out to dinner and drinks, with a wealthy man, but that she would not be required to have sex. 10. On or about November 4, 2015, Plaintiff travelled to Washington DC, from New York City, to visit a friend, 11. On the night of November 4, 2015, Minton sent Plaintiff a text message, which instructed Plaintiff that she would be meeting a guy named “Howie” for lunch tomorrow, at the Russian Tea Room, in Manhattan. 12, On November 5, 2015, Plaintiff and her friend, travelled from Washington DC back to New York City. 13, Shortly after Plaintiff's arrival in New York, she deposited her luggage at the apartment she was staying at, and prepared for her date with Defendant Rubin, at the Russian Tea Room in Manhattan, located at 157 W. 57" Street. 14, Ms. Parker was told by Minton to arrive at the Russian Team Room at, or around, 2pm, on November 5, 2015. 15. The information Plaintiff received regarding Rubin, was that she would be having lunch with a really nice guy in his 40°s that went by the name “Howie.” 16, When Ms, Parker arrived, Defendant Rubin was not yet there, as such, she was escorted by the host to their reserved table. 2 of 19(FILED: NEW YORK COUNTY CLERK 04/06/2018 06:29 PM BDEE Boe codtse/ 2028) NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 08/06/2018 17. Defendant Rubin ordered some expensive caviar, and their first round of alcoholic drinks from their waiter, which upon information and belief, was 2 glasses of Don Julio 1942 Anejo, neat. A very expensive tequila that is 80 proof (or 40% alcohol by volume). 18. Thereafter, Defendant Rubin engaged Ms. Parker in conversation, and continuously asked her to drink “more” and get “comfortable”. Both Defendant Rubin and Ms, Parker ordered. additional food and alcoholic beverages in the restaurant. 19, Defendant Rubin and Ms. Parker had multiple alcoholic drinks over the course of a couple hours at the restaurant. 20. Defendant Rubin and Ms, Parker talked for well over an hour, about, among other things, Defendant Rubin’s lifestyle and wealth, and Plaintiff's interests and ambitions to go to college. 21. Defendant Rubin indicated to Plaintiff that if he liked her, he would fly her to Miami to watch some baseball or basketball game that he had floor seats to. 22. Defendant Rubin and Ms. Parker got along well in the beginning of their date, and he appeared to be a genuinely nice person, who was interested in talking to Ms. Parker, and getting to know her. 23. During their date, Defendant Rubin continued to insist that Ms. Parker drink and relax. Ms, Parker complied, and was served accordingly by the Russian Tea Room, without once being asked for any identification, and after both her, and Defendant Rubin had been at the restaurant for more than an hour. 24. Plaintiff was just 20 years old. 25. At some point, during their date, Defendant Rubin’s assistant ‘Stephanie’, came into the restaurant, and presented Plaintiff with a non-disclosure agreement (“NDA”). 3 of 19

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