GREENEVILLE, Tenn. (WJHL) — Attorneys in an alleged sexual assault-based civil suit against Johnson City, its police department and several officers want to broaden their complaint to a class action that would include at least two classes and lead to an expansion beyond the current nine plaintiffs.

An amended complaint filed Friday, which still requires a judge’s approval, also introduces a 10th plaintiff — the first one who claims to be a victim of someone other than former downtown businessman and alleged serial rapist Sean Williams.

“Jane Doe 10” lives in a neighboring state and was allegedly sexually assaulted in November 2021, when she was 17, while on a visit to family friends in Johnson City. 

Jane Doe 10’s mother learned Aug. 25 about allegations that the Johnson City Police Department (JCPD) had mishandled sexual assault cases. That’s when she saw on Fox News’s website a News Channel 11 exclusive story about North Carolina polices’ discovery of images allegedly showing Williams sexually assaulting more than 50 different women in his downtown Johnson City apartment.

Jane Doe 10 would join alleged Williams victims Jane Does 2, 5 and 7 in a so-called “reporter survivor class,” constituting “All women, including minors, who reported sexual abuse or trafficking by any person to JCPD from January 1, 2018, to April 25, 2023,” the amendment reads. Those four all have police reports or investigations linked to their cases, though no charges were ever filed in any of them. 

Williams was arrested in Cullowhee, N.C. April 29 when officers allegedly discovered more than three-fourths of a pound each of cocaine and methamphetamine in his car. The arrest came nearly two years after JCPD officers unsuccessfully tried to serve a federal warrant on him at his downtown apartment.

He has been jailed since and was transferred to federal custody the first week of May and faces a Nov. 2 federal trial on ammunition and attempted escape charges.

The other class listed in Friday’s amended complaint — the “conspiracy survivor class” — includes anyone “sexually abused, drugged, or trafficked by Sean Williams” or by an alleged accomplice named in the suit.

The conspiracy reference is to an alleged conspiracy in which certain JCPD officers allowed Williams to allegedly drug and rape dozens of women in his downtown apartment in exchange for “financial benefits.” Those allegations are outlined in an earlier amendment to the suit, filed a week ago.

The proposed class action, if approved, will bring a third law group into the plaintiffs’ complaint. They’re currently represented by Vanessa Baehr-Jones of Oakland, Calif-based Advocates for Survivors of Abuse and three attorneys from Brentwood-based HMC Civil Rights Law. The class action attorney requesting admission to the case is Elizabeth Kramer of San Francisco-based Erickson Kramer Osborne, which specializes in sexual abuse and cryptocurrency-related class action suits.

The amended complaint is the second filed within two weeks. The initial suit was filed June 21, 2023 and names the city, JCPD, and three officers individually — chief Karl Turner and captain Kevin Peters, now retired, and investigator Toma Sparks. The first amended complaint adds investigator Justin Jenkins.

It alleges multiple constitutional violations and failure by the city to adequately train and supervise. Johnson City has filed an answer to the initial complaint and denied all the allegations.

Jane Doe 10 family: groping case inadequately investigated

The latest entrant to the case cites many of the same claims about inadequate policing and investigating that are claimed by the alleged Williams victims. Among them are alleged failure to collect an important piece of evidence, failure to interview the suspect and bringing up Jane Doe 10’s past as a possible impediment to successful prosecution.

Jane Doe 10 was on a trip to Johnson City for Thanksgiving week in 2021, where she planned to care for a girl she regularly babysat and spend the holiday with the girl’s family, who was friends with her family.

The suit claims that at a point during the visit, Jane Doe 10 was with the young girl, the girl’s grandfather, and his son-in-law along with four other children.

At a certain point the younger man approached Jane Doe 10 when she was alone in the kitchen and allegedly groped her for several minutes through her clothing after she initially “froze in shock,” the complaint says.

Jane Doe 10 called her older sister and parents the next morning, and her parents told her to report the incident to the alleged perpetrator’s parents-in-law.

“After hearing Jane Doe 10’s account, (the father-in-law) told Jane Doe 10 that this explained a text message he had received that morning from (the alleged perpetrator) which stated that something might have happened the night before with Jane Doe 10,” the suit states.

Jane Doe 10’s mother called a rape crisis center in their home state, which told her they would call Tennessee’s Department of Children’s Services and report the incident.

On Dec. 10, a JCPD investigator, Kara Lowe, called Jane Doe 10’s mother saying she’d received a report about the girl’s alleged sexual battery and would be investigating. The lawsuit says Jane Doe 10 underwent a forensic interview in her hometown and that recording was sent to JCPD.

Jane Doe 10’s parents claim to have checked back about a month later having not heard anything from JCPD and asked whether Lowe had received the interview. Several weeks after that, Lowe allegedly told them she didn’t expect the First Judicial District Attorney’s Office would pursue charges.

Lowe allegedly cited “several reasons, none of which appeared to Jane Doe 10’s parents to be proper reasons to close the case.” The purported reasons included Jane Doe 10’s mental health from having survived a previous rape, as well as the alleged perpetrator having hired “an expensive, high powered defense attorney … who was arguing that Jane Doe 10 lacked credibility based on her past.”

Lowe allegedly said the DA “did not want to put Jane Doe 10 through the difficult process of testifying,” the suit says.

“Jane Doe 10’s parents insisted, however, that it was not appropriate to close the case,” the suit reads. “This case was important both for their daughter and because (the man) was in a position of authority around children.” (He had been the dean of a school Jane Doe 10 attended prior to moving to Johnson City.)

The parents pressed Lowe despite other reasons she stated for closing the case, the suit says. After Lowe told them she would call back if the DA decided to pursue charges, they never heard back despite leaving “voicemails for Investigator Lowe imploring her to use criminal process to obtain the text message and to continue to investigate their daughter’s case.”

No charges have been filed in the case, and the suit claims the alleged perpetrator is now a pastor at a church.

More plaintiffs in the pipeline?

The second amended complaint, like the earlier amendment, leans heavily on recent information that has come to light.

Primarily, that includes the Daigle Law Group (DLG) report commissioned by the city and released July 18, as well as the News Channel 11 story about the videos and photos allegedly found in Williams’ possession when he was arrested.

Friday’s complaint alleges that Jane Doe 10 and “other members of the Reporter Survivor Class who were not victims of Williams” may have been “devastated, confused, and shocked by JCPD’s failure to properly investigate their cases,” but wouldn’t have suspected “this conduct was part of a pattern and practice of discriminatory conduct towards female victims of sexual violence” prior to the Daigle report.

It also cites press coverage, including recent national coverage of the Williams-related cases, as another avenue through which potential victims may learn about the issue.

They cited a “liberal amendment standard” and said they acted quickly to complete the second amendment, “particularly considering the complex nature and rapidly developing facts concerning the conduct challenged in the lawsuit.”

Finally, the motion says since the June filing, “additional survivors have come forward and expressed a desire to be involved in the lawsuit as either a class representative, or as unnamed class members.”

The plaintiffs’ attorneys also request an option to modify the classes, including expanding the time period eligible for plaintiffs to earlier than 2018 and to creating additional “subclasses” to the suit.

News Channel 11 requested comment from the City of Johnson City after the motion to amend was filed Friday afternoon and was awaiting a statement at the time of publication.