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SANDERS LAW GROUP 638 CAMINO DE LOS MARES, SUITE H130-510 SAN CLEMENTE, CA 92673 (310) 574-2754

SANDERS LAW GROUP Inga N. Sanders (State Bar No. 221552) isanders@sanderslg.com 638 Camino De Los Mares, Suite H130-510 San Clemente, CA 92673 Telephone: (310) 574-2754 Facsimile: (310) 997-3626 RUTAN & TUCKER, LLP Alejandro S. Angulo (State Bar No. 217823) aangulo@rutan.com 611 Anton Boulevard, Fourteenth Floor Costa Mesa, California 92626-1931 Telephone: (714) 641-5100 Facsimile: (714) 546-9035 ATTORNEYS FOR PLAINTIFFS Kelli Peters, Bill Peters and MINOR 1

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE KELLI PETERS, an individual, BILL PETERS, an individual, and MINOR 11, a minor child, by and through her guardian ad litem, Kelli Peters Plaintiffs, vs. JILL B. EASTER, an individual, KENT W. EASTER, an individual, and DOES 1 through 20, inclusive, Defendants. Case No. COMPLAINT FOR: 1. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; 2. NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS; AND 3. FALSE IMPRISONMENT (Unlimited Civil Case) JURY TRIAL DEMANDED

C-32

The name MINOR 1 used in this complaint is a pseudonym used to protect the identity of Mr. and Mrs. Peters minor child. The true name of Minor 1will be filed with the court under seal.
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COMPLAINT

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SANDERS LAW GROUP 638 CAMINO DE LOS MARES, SUITE H130-510 SAN CLEMENTE, CA 92673 (310) 574-2754

Plaintiffs Kelli Peters, Bill Peters and MINOR 1 (Plaintiffs) allege the following:

THE PARTIES 1. Plaintiff Kelli Peters is and was at all relevant times an individual residing in Orange

County, California. 2. Plaintiff Bill Peters is and was at all relevant times an individual residing in Orange

County, California, and husband to Kelli Peters. 3. Plaintiff MINOR 1 is and was at all relevant times a minor child residing in Orange

County, California, with her parents Kelli and Bill Peters, and appears in this action by and through her guardian ad litem, Kelli Peters. 4. Plaintiffs are informed and believe and thereon allege that defendant Jill B. Easter,

also known as Ava Bjork and Jill Bjorkholm, is and was at all relevant times an individual residing in Orange County, California. 5. Plaintiffs are informed and believe and thereon allege that defendant Kent W. Easter

is and was at all relevant times an individual residing in Orange County, California. 6. Plaintiffs are unaware of the true names and capacities of defendants Does 1 through

20, inclusive, and therefore sue these defendants by such fictitious names. Plaintiffs will amend this Complaint to show the true names and capacities of such fictitiously named defendants when the same have been ascertained or upon proof at trial. Plaintiffs are informed and believe and based thereon allege that each of the fictitiously-named defendants are legally responsible for the events and damages alleged herein and/or jointly and severally liable for the debts and obligations of other defendants as alleged herein. 7. Plaintiffs are informed and believe and based thereon allege that at all relevant times,

certain of the defendants, including the Doe defendants, were acting as the partners, agents, coconspirators, successors or predecessors in interest, and, unless alleged otherwise, were acting within the course and scope of such relationship, with the knowledge, express or implied, of each such other named defendants. Jill B. Easter, Kent W. Easter, and Does 1-20 are collectively referred to herein as Defendants.

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COMPLAINT

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SANDERS LAW GROUP 638 CAMINO DE LOS MARES, SUITE H130-510 SAN CLEMENTE, CA 92673 (310) 574-2754

OPERATIVE FACTS 8. 9. All operative facts are pleaded on information and belief. This unfortunate case arises from an evil conspiracy by Jill and Kent Easter to

destroy the lives of Kelli Peters, her husband Bill Peters, and their twelve year old child, MINOR 1. 10. Beginning in or about early 2011, the Easters conspired and plotted to have Kelli

Peters arrested, criminally convicted and imprisoned for crimes associated with unlawful possession of narcotics and illegal drugs, child endangerment, and driving under the influence, among other things. 11. At all relevant times, Mrs. Peters was a member of the PTA and worked as a

volunteer at a local elementary school, where her child, MINOR 1, also attended. 12. On or about February 16, 2011, Mr. Easter, pursuant to his conspiracy with Mrs.

Easter, planted Vicodin, Percocet, Marijuana, and a used Marijuana pipe in the back seat of Mrs. Peters car. As part of the conspiracy to frame Mrs. Peters, Mr. Easter made sure to plant these items in plain view. 13. After planting the drugs and pipe in Mrs. Peters car and pursuant to his conspiracy

with Mrs. Easter, Mr. Easter called the Irvine police, falsely telling the police that he was a concerned parent who had witnessed Mrs. Peters driving erratically in the parking lot of the elementary school, where children were present. Also pursuant to the conspiracy, Mr. Easter falsely told the police that he had witnessed Mrs. Peters (a) park her car at the elementary school; (b) use drugs in her car, (c) place a large quantity of illegal drugs in the backseat of her car in plain view; and (d) enter the school where numerous children were present. In furtherance of his conspiracy and in an attempt to cover his tracks, Mr. Easter gave the police a phony name, telephone number and address. 14. Concerned about the well-being and safety of elementary school children, the Irvine

Police acted on Mr. Easters false report and went to the school to investigate. When Irvine police officers arrived at the school, they found Mrs. Peters car in the parking lot, looked through the window, and saw the bag of drugs behind the drivers seat, just as Mr. Easter had described in his phony police report. The police officers then entered the school, tracked down Mrs. Peters and, in

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COMPLAINT

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SANDERS LAW GROUP 638 CAMINO DE LOS MARES, SUITE H130-510 SAN CLEMENTE, CA 92673 (310) 574-2754

front of children, parents, school administrators, volunteers and Mrs. Peters twelve year old child, took Mrs. Peters into custody and escorted her outside the building. 15. When police first took Mrs. Peters into custody, Mrs. Peters was immediately

distraught, believing that something terrible must have happened to her husband, and that the police were there to notify her of his death. After a few moments, however, Mrs. Peters learned that the police were in fact following up on a tip that she had been driving erratically around the elementary school parking lot, was on drugs, and had stashed a bag of drugs in the back of her car. Mrs. Peters was shocked at the accusation. 16. In a desperate effort to clear her name, Mrs. Peters consented to a search of her car,

still hoping that this was all some sort of terrible misunderstanding. Mrs. Peters was escorted to her car and discovered that it was surrounded by police cars and onlookers, and that a police helicopter was circling overhead. To Mrs. Peters horror, when the police opened her car, they pulled out the bag of drugs and drug paraphernalia. In front of a crowd of people, including the police, the entire school, parents, volunteers, passersby and Mrs. Peters twelve year old child, the police laid out the Vicodin, Percocet, Marijuana and Marijuana pipe on the hood of a nearby police car. Mrs. Peters was then forced to sit on the curb in the school parking lot next to the array of drugs and drug paraphernalia, for all to see. Mrs. Peters was detained at the school for over two hours while the police conducted their investigation. Distraught and afraid, Mrs. Peters was crying and shaking uncontrollably. 17. While Mrs. Peters was being detained by police, the school principal notified Mr.

Peters that his wife had been taken into custody and that he needed to come down to the school immediately. Fearing for his wife, Mr. Peters immediately left work and rushed over to the school, where he found his wife being held by police on suspicion of illegal drug use and drug possession. Mr. Peters was horrified. 18. Continuing their investigation of Mrs. Peters and pursuant to police protocol, the

police then escorted Mrs. Peters and her family back to their home, where they conducted a search of the premises. While Mrs. Peters, her husband and their young daughter watched in nervous shock, the police searched their home, including bedrooms, bathrooms, the garage and the patio.

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SANDERS LAW GROUP 638 CAMINO DE LOS MARES, SUITE H130-510 SAN CLEMENTE, CA 92673 (310) 574-2754

Later that night, CSI showed up at the Peters home and took DNA samples of Mrs. Peters, Mr. Peters and their child with intrusive cheek swabs. CSI also conducted fingerprint analyses of the family and their car. 19. During her detention by police and the continued criminal investigation, Mrs. Peters

was faced with the prospect of being convicted for felony drug possession, felony child endangerment, and driving under the influence, among other thingsoffenses which would not only cause her to lose her volunteer job and be disgraced in her community, but potentially send her to jail for years and rip her away from her child and husband. Understandably, throughout the detention, police search and CSI investigation, the Peters hearts were beating out of their chests. 20. The Peters suffering did not end after the day on which Mrs. Peters was detained,

however. Over the next year, the Irvine police continued to investigate the matter. Throughout this time, the Peters remained fearful that someone was out to hurt or kill them, and that Mrs. Peters might still be arrested and convicted of crimes she did not commit. Every time the Police called Mrs. Peters or had her come down to the police station seeking more information about the incident, Mrs. Peters and her family thought that she was going to be thrown in jail. Mrs. Peters, Mr. Peters and their daughter felt helpless and terrified throughout the entire ordeal. 21. During the initial detention of Mrs. Peters and the subsequent police inquiry, the

Peters family was forced to endure extreme distress, fear, and public humiliation from the criminal investigation and accusations, as well as the constant anxiety that some unknown person or persons were actively trying to destroy them. Mrs. Peters has suffered and continues to suffer from panic and depression due to this ordeal. She has had difficulty sleeping and experienced recurring nightmares about being arrested or about being murdered by an unknown attacker. In fact, in one recurring nightmare, an unknown assailant breaks into her home and slits her throat before killing the rest of her family in cold blood. 22. Mr. Peters was and remains fearful for the safety of his family, and has constant

anxiety about leaving his family alone while at work. After discovering that unknown assailants were out to get his family, Mr. Peters began calling home eight to ten times a day to check on his wife and child. Mr. Peters anxiety grew so severe that he experienced panic attacks.

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SANDERS LAW GROUP 638 CAMINO DE LOS MARES, SUITE H130-510 SAN CLEMENTE, CA 92673 (310) 574-2754

23.

The Peters twelve year old child, MINOR 1, has also suffered and continues to

suffer from severe anxiety and depression, and is afraid to fall asleep alone. After the incident, MINOR 1 would wake up in the middle of the night, terrified, and run to her parents bedroom where she cried herself to sleep in her mothers arms. To this day, she remains fearful and has difficulty sleeping. Once a popular and successful student, MINOR 1 has become withdrawn at school and has been isolated from her classmates. MINOR 1 has had difficulty concentrating on her schoolwork and her grades have suffered. Since this incident, MINOR 1 has been singled out and shunned by other students. 24. After a lengthy and incredibly thorough investigation, the Irvine police were able to

trace the call made by Mr. Easter to a hotel lobby, where surveillance footage revealed his identity. The police also found DNA from both Mr. and Mrs. Easter on the drugs and Marijuana pipe that were planted in Mrs. Peters car, and uncovered numerous text messages and emails sent between Mr. and Mrs. Easter regarding their plot to destroy Mrs. Peters and her family. On or about June 16, 2012, the Irvine police arrested Jill and Kent Easter. 25. After their arrest on June 16, 2012, the Easters were charged with (1) conspiracy to

falsely charge or indict another of a crime; (2) false imprisonment effected by violence, menace, fraud, or deceit; and (3) conspiracy to commit a crime. The criminal case is currently pending in Orange County Superior Court, Case No. 12CF1831. Accordingly, Plaintiffs did not learn that Defendants were the persons responsible for the conduct alleged herein until well within any applicable statutes of limitations periods. 26. The arrest and indictment of Jill and Kent Easterboth of whom are wealthy,

extremely well educated and powerful attorneysmade headlines around the nation and across the globe. Prior to and even after their arrest, the Easters have shown absolutely no remorse for their despicable conduct, which has ripped apart the lives of the entire Peters family. Despite the overwhelming evidence against them, including DNA evidence, text messages, emails, and video surveillance, the Easters continue to deny responsibility and, incredibly, Jill Easter, aka Eva Bjork, continues to market her novel about how to commit the perfect crime.

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COMPLAINT

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SANDERS LAW GROUP 638 CAMINO DE LOS MARES, SUITE H130-510 SAN CLEMENTE, CA 92673 (310) 574-2754

FIRST CAUSE OF ACTION (Intentional Infliction of Emotional Distress - By Plaintiffs against all Defendants) 27. Plaintiff re-alleges and incorporates by reference the allegations set forth in

paragraphs 1 through 26 of this Complaint as if fully set forth herein. 28. Prior to the conduct alleged herein, Defendants knew that Kelli Peters was married

to Bill Peters and that they had a twelve year old child, MINOR 1, who attends the elementary school where Mrs. Peters volunteers. 29. Defendants conduct alleged herein was extreme and outrageous. Defendants knew

their conduct would inflict severe emotional distress on not only Kelli Peters, but on her husband and daughter as well, or that such injuries were substantially certain to result. 30. As a direct and proximate result of the aforementioned acts, Plaintiffs have suffered

general and special damages, including pain and suffering, humiliation, mental anguish, and serious emotional and physical distress, in an amount which exceeds jurisdictional minimums to be proven at trial. 31. The above-described conduct of Defendants was despicable, and was perpetrated

with malice, oppression and/or reckless disregard for the rights and safety of Plaintiffs. Plaintiffs are therefore entitled to recover exemplary and punitive damages against Defendants. SECOND CAUSE OF ACTION (Negligent Infliction of Emotional Distress - By Plaintiffs against all Defendants) 32. Plaintiffs re-allege and incorporate by reference the allegations set forth in

paragraphs 1 through 31 of this Complaint as if fully set forth herein. 33. Defendants had a general duty not to cause severe emotional distress to Mrs. Peters

or her family. Defendants breached this duty by committing the acts alleged herein. 34. Defendants should have known that their conduct would inflict severe emotional

distress on Plaintiffs, or that such injury was substantially certain to result. 35. As a direct and proximate result of the aforementioned acts, Plaintiffs have suffered

general and special damages, including pain and suffering, humiliation, mental anguish, and serious emotional and physical distress, in an amount which exceeds jurisdictional minimums to be proven

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COMPLAINT

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SANDERS LAW GROUP 638 CAMINO DE LOS MARES, SUITE H130-510 SAN CLEMENTE, CA 92673 (310) 574-2754

at trial. 36. The above-described conduct of Defendants was despicable, and was perpetrated

with malice, oppression and/or reckless disregard for the rights and safety of Plaintiffs. Plaintiffs are therefore entitled to recover exemplary and punitive damages against Defendants. THIRD CAUSE OF ACTION (False Imprisonment - By Kelli Peters against all Defendants) 37. Mrs. Peters re-alleges and incorporates by reference the allegations set forth in

paragraphs 1 through 36 of this Complaint as if fully set forth herein. 38. On or about February 16, 2011, Mrs. Peters was confined by the Irvine Police

against her will for over two hours, under threat of arrest. 39. The confinement/arrest of Mrs. Peters was made at the request and insistence of

Defendants, and Defendants took an active role in bringing about this confinement/arrest through the intentional, fraudulent and deceitful acts alleged herein. 40. As a direct and proximate result of the aforementioned acts, Mrs. Peters has suffered

general and special damages, including pain and suffering, humiliation, mental anguish, and serious emotional and physical distress, in an amount which exceeds jurisdictional minimums to be proven at trial. 41. The above-described conduct of Defendants was despicable, and was perpetrated

with malice, oppression and/or reckless disregard for the rights and safety of Mrs. Peters. Mrs. Peters is therefore entitled to recover exemplary and punitive damages against Defendants. WHEREFORE, Plaintiffs pray for judgment against all Defendants as follows: a. For special damages according to proof; b. For prejudgment interest as allowed by law; a. For general damages according to proof; /// /// /// ///

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SANDERS LAW GROUP 638 CAMINO DE LOS MARES, SUITE H130-510 SAN CLEMENTE, CA 92673 (310) 574-2754

b. For punitive damages as allowed by law; c. For cost of suit herein; d. For reasonable attorneys fees as allowed by law; and e. For such other and further relief as the Court deems just and proper.

Dated: August 3, 2012

SANDERS LAW GROUP By:__________________________________ Inga N. Sanders Attorneys for Plaintiffs Kelli Peters, Bill Peters, and MINOR 1

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