Defendants engaged in “willful misconduct, malice,… wantonness,

oppression, or that entire want of care which would raise the presumption

of conscious indifference to consequences” entitling Plaintiff to punitive

damages under O.C.G.A. § 52-12-5.1.

PARTIES, JURISDICTION, AND VENUE

2. Plaintiff is a resident of Dade County, Florida, and voluntarily submits to

the jurisdiction of this Court.

3. Defendant The Haunt, LLC, is a limited liability company whose principal

office address and address for service of process is

Savannah, Georgia, 31401.

4. Defendant Clayton Ehmke is the registered agent for service of process for

The Haunt, LLC.

5. The address , Savannah, Georgia, 31401 is the location of

The Haunt Restaurant.

6. Defendant Clayton Ehmke also resides at , Savannah,

Georgia, 31401.

7. Ehmke does not intend to remain in Chatham County, Georgia.

8. Ehmke currently is attempting to sell The Haunt Restaurant and relocate to

New York so as to remove assets subject to this Complaint from the

jurisdiction of this Court.

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 9. This Court nonetheless retains personal jurisdiction over Ehmke pursuant

to O.C.G.A. § 9-10-91(1) and (2).

10. Personal jurisdiction is proper as to The Haunt, LLC pursuant to O.C.G.A.

§ 9-10-91(1) and (2).

11. This Court has subject matter jurisdiction over this action.

12. Venue in Chatham County, Georgia, is proper.

FACTS

13. Paragraphs 1 through 12 are incorporated as if fully restated herein.

14. During the late-night hours of June 30, 2021, Plaintiff was invited by Ehmke

to an “after party” at his restaurant, The Haunt, located at

Savannah, Georgia, 31401.

15. Dan, who is an acquaintance of Ehmke, also attended the “after party.”

16. Plaintiff’s female friend, referred to herein as “ ”2 accompanied

Plaintiff to The Haunt.

17. Ehmke was aware when he invited Plaintiff to The Haunt that Plaintiff was

engaged in a sexual relationship with

2Although full name is known to Plaintiff, her surname is omitted, both to maintain her
privacy and because of an ongoing Savannah Police Department criminal investigation into Ehmke’s
actions toward

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 18. Ehmke’s residence above The Haunt is strategic, as it allows Ehmke to

sexually pursue women in relation to operation of The Haunt.3

19. During the “after party,” which consisted only of the four individuals

named in this complaint, Plaintiff and engaged in sexual intercourse in

the office of The Haunt.

20. During the time Plaintiff and were engaged in intercourse, Ehmke

sexually pursued in his residential quarters above the restaurant.

21. Plaintiff was unaware that the office of the then-unopened restaurant

contained surveillance cameras.

22. Ehmke knew that Plaintiff and engaged in sexual activity in the office

of The Haunt.

23. After Plaintiff and departed the premises, Ehmke reviewed office

security camera footage for the purpose of viewing Plaintiff and

engaged in sexual activity.

24. Ehmke then distributed security camera footage of Plaintiff and

engaged in intercourse to several individuals.

25. The individuals to whom Ehmke distributed this security camera footage

then re-distributed the footage to other individuals.

3Sean Evans, Protestors at Savannah Restaurant Demand Accountability in Restaurant Industry, WTOC-TV
(Aug. 18, 2021), https://www.wtoc.com/2021/08/18/protestors-savannah-restaurant-demand-
accountability-restaurant-industry/.

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26. Ehmke knew, or should have known, that this security camera footage

would be re-distributed to other individuals.

27. As a result of this embarrassing circulation of an intimate sexual encounter,

Plaintiff suffered traumatizing harassment.

28. This harassment included individuals whom Plaintiff was not acquainted

with visiting the downtown Savannah bar where Plaintiff worked as a

bartender to harass her, telling her “ is a lucky guy,” and asking “When

is my turn?”

29. Individuals with whom Plaintiff was acquainted made similar harassing

comments.

30. As a result of this harassment, Plaintiff suffered severe mental and

emotional distress, and moved to Miami, Florida, for the purpose of

escaping the humiliation caused by Ehmke’s acts.

COUNT I: VIOLATION OF O.C.G.A § 16-11-62

31. Paragraphs 1 thorough 30 are incorporated as if fully restated herein.

32. Defendants “without the consent of all persons observed… observe[d]

[and] record[ed] the activities” of Plaintiff and in a “private place and

out of public view” in violation of O.C.G.A. § 16-11-62(2).

33. Defendants did not observe and record these activities “for security

purposes, crime prevention, or crime detection” but instead observed the

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 activities for the purposes of sexual gratification and the humiliation of

Plaintiff and Dan. O.C.G.A. § 16-11-62(2)(C).

34. Defendants “distribute[d], without legal authority” video surveillance

and/or “copies thereof,” embarrassing, intimate video of Plaintiff and

in a “private place and out of public view” without the consent of Plaintiff

and in violation of O.C.G.A. § 16-11-62(6).

35. Defendants’ acts were in violation of O.C.G.A. § 16-11-62(7).

36. As a result of Defendants’ violations of O.C.G.A. § 16-11-62, Plaintiff

suffered embarrassment, humiliation, harassment, and mental and

emotional distress.

COUNT II: INTRUSION UPON SECLUSION

37. Paragraphs 1 though 36 are incorporated as if fully restated herein.

38. Defendants’ observation and circulation of security camera footage of

Plaintiff and engaged in sexual intercourse was unreasonable prying

or intrusion into private concerns that would be offensive or objectionable

to a reasonable person.

39. As a result of Defendants’ intrusion upon Plaintiff’s seclusion, Plaintiff

suffered embarrassment, humiliation, harassment, and mental and

emotional distress.

COUNT III: PUBLIC DISCLOSURE OF EMBARASSING PRIVATE FACTS

40. Paragraphs 1 through 30 are incorporated as if fully restated herein.

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41. Defendants publicly disclosed video surveillance of Plaintiff and

engaged in sexual intercourse.

42. Plaintiff’s and sexual intercourse was a private, secluded fact.

43. Defendants’ actions were offensive and objectionable to a reasonable

person of ordinary sensibilities under the circumstances.

44. As a result of Defendants’ embarrassing disclosure of private facts,

Plaintiff suffered embarrassment, humiliation, and mental and emotional

distress.

COUNT IV: PUNITIVE DAMAGES

45. Paragraphs 1 through 44 are incorporated as if fully restated herein.

46. Defendants engaged in “willful misconduct, malice,… wantonness,

oppression, or that entire want of care which would raise the presumption

of conscious indifference to consequences” entitling Plaintiff to punitive

damages under O.C.G.A. § 52-12-5.1.

PRAYER FOR RELIEF

47. Plaintiff prays for judgment and relief against Defendants as follows:

a. That this Court exercise its equitable jurisdiction to require

Defendants to place in trust with this Court any and all assets

acquired from the sale of The Haunt Restaurant until the resolution

of this action;

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 b. That judgment be entered for Plaintiff and against Defendants for

past, present, and future compensatory damages;

c. That judgment be entered for Plaintiff and against Defendants for

punitive damages in and amount to deter, penalize, and punish

Defendants in light of the circumstances of the case;

d. For an award of attorneys’ fees, expenses, and costs; and

e. For any and all relief that this Court deems equitable and proper.

JURY DEMAND

Plaintiff demands a trial by jury on all causes of action so triable.

Dated: Sept. 17, 2021.

s/ Constance Cooper
Constance Cooper
GA Bar No: 469041
1505 Washington Avenue
Savannah, GA 31404

Frank R. Schirripa (pro hac vice

forthcoming)
HACH ROSE SCHIRRIPA
& CHEVERIE LLP
112 Madison Avenue, 10th Floor
New York, New York 10016
Tel: (212) 213-8311
ccooper@hrsclaw.com
fschirripa@hrsclaw.com

Counsel for Plaintiff