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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

BRITTON ESPOSITO, CHRISTIAN FRESNO, )

BENJAMIN KUTYLO, ALLYSON ESPOSITO, )

AND ALLYSON ESPOSITO AS MOTHER AND )

NEXT FRIEND OF JANIE DOE, A MINOR, )

)

Plaintiffs, )

)

v. ) Case No. 1:20-cv-2713

)

AIRBNB ACTION, LLC; AIRBNB )

PAYMENTS, INC.; AIRBNB, INC.; ) JURY TRIAL DEMANDED

PUERTO PANAL FARM CLUB PROPERTY )

ASSOCIATION AND ASSOCIATION BOARD, )

MATIAS JOSE FERNANDEZ, )

LINDSAY OLSON, AND OTHER OWNER(S) )

AND/OR AIRBNB HOSTS OF FARM HOUSE )

CHAKRA 82, BUENOS AIRES, ARGENTINA, )

)

Defendants. )

COMPLAINT

COME NOW, the Plaintiffs, BRITTON ESPOSITO (“Britton”), CHRISTIAN FRESNO 

(“Christian”), BENJAMIN KUTYLO (“Benjamin), ALLYSON ESPOSITO (“Allyson”), and 

ALLYSON ESPOSITO AS MOTHER AND NEXT FRIEND OF JANIE DOE A MINOR

(“Toddler Janie Doe”) (jointly, “Plaintiffs”), by and through their counsel Nicholas F. Esposito and 

Bradley K. Staubus, and for their Complaint against Defendants (jointly “Defendants”) and each of 

them: AIRBNB ACTION LLC (“AIRBNB Action”), AIRBNB PAYMENTS, INC. (“AIRBNB

Payments”), AIRBNB, INC. (“AIRBNB”); PUERTO PANAL FARM CLUB PROPERTY 

ASSOCIATION AND ASSOCIATION BOARD (“Farm Club”); MATIAS JOSE FERNANDEZ

(“Fernandez”), LINDSAY OLSON (“Olson”) OWNER(S)/HOSTS (“Host(s)”) of FARM HOUSE 

CHAKRA 82, BUENOS AIRES, ARGENTINA (“Farm House”); and allege as follows:
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SUMMARY

1. The Airbnb Platform is an online marketplace that enables registered users 

(“Members”) and third parties (“Owners/Hosts”) offering real estate rental services (“Host 

Services”) to publish on and through the Airbnb Platform (“Listings”) such real estate rentals in 

communication through AIRBNB to AIRBNB Members that are seeking to book such Host 

Services. Members using Host Services are “Guests”. Host Services may include the offering of 

vacation or other properties ("Accommodations"), single or multi-day usage (“Experiences”).

See, https://www.airbnb.com/terms?source=tos.

2. Britton and Christian became wife and husband on November 14, 2019 in Buenos 

Aires, Argentina (the “Wedding”) in the presence of Benjamin and Allyson and their daughter 

Toddler Janie Doe, a minor, and others. Several days later, on November 21, 2019, Allyson 

through AIRBNB made a several-day Guest reservation to rent the Farm House, Chakra 82, 

Buenos, Argentina, located in a remote gated and guarded community outside Buenos Aires. It is 

advertised as such by AIRBNB. Anyone entering the property by vehicle would have to do so 

through the main gate and past two security guards. 

3. Near midnight of November 21, 2019, Britton, Christian, Benjamin, Allyson and 

Toddler Janie Doe were in the quiet of the AIRBNB rental Farm House. Four (4) masked men

dressed in black carrying guns and knives (“Assailants”) entered the Farm House, tied and gagged 

Plaintiffs, and held them hostage for more than three (3) hours. Plaintiffs were assaulted, battered, 

robbed and traumatized, causing physical, emotional and financial damage. The security company 

was hired by Defendant Hosts and Farm Club. The two security guards had not been held hostage,

nor injured and, on information and belief, were considered accomplices.
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4. The events directly resulted from Defendants’ collective and separate negligence, 

misrepresentation, deception and misfeasance about the property’s safety and management.

JURISDICTION AND VENUE

5. Article III, Section 2 of the United States Constitution extends the judicial power of 

federal courts to “all Cases ... between a State, or the Citizens thereof, and foreign States, Citizens 

or Subjects.”

6. This Court also is given jurisdiction of this matter under 28 U.S.C. § 1332(a), which 

provides for jurisdiction over citizens of a State and citizens or subjects of a foreign state where the 

amount in controversy exceeds $75,000. Complete diversity exists as here with foreign parties on 

both sides of the litigation under section 1332(a)(3) as there are citizens of the United States on 

both sides.

7. The amount in controversy in this matter exceeds $75,000.

8. This Court has personal jurisdiction over the Defendants because they have 

sufficient contacts in Illinois, and the rest of the United States, to render the exercise of jurisdiction 

by this Court permissible. The conduct of Defendants described below arises out of commercial 

activities that have caused a direct effect in the United States and in the State of Illinois, including, 

but not limited to: (1) operation of a real property rental system headquartered in San Francisco, 

United States of America, and in every state of the United States and in foreign countries worldwide 

including Buenos Aires, Argentina; (2) and the operation of traditional and social media platforms 

for commercial gain worldwide including in the United States and Argentina.

9. Pursuant to 28 U.S.C. § 1331, this Court also has federal question jurisdiction in all 

civil actions arising under the Constitution, laws, or treaties of the United States. 
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10. Pursuant to 28 U.S. Code § 1367, this Court also has supplemental jurisdiction over 

Plaintiffs’ state claims set forth herein that are so related to claims in the action within such original 

jurisdiction that they form part of the same case or controversy under Article III of the United States

Constitution.

11. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)(2) and (c) because 

there are sufficient contacts in the United States and Illinois to render the exercise of jurisdiction 

by this Court permissible. 

Plaintiffs Britton, Allyson and Allyson’s daughter Toddler Janie Doe, and Benjamin are 

citizens of the United States. Britton is domiciled in Cook County, Illinois and attends school in 

Argentina. Plaintiff Christian is a citizen of Argentina.

Defendant AIRBNB is headquartered in California. AIRBNB is registered to do business in 

the State of Illinois and does business in Illinois including in Cook County, Illinois. Defendant

Farm Club is a citizen of Argentina. Defendant Fernandez is a citizen of Argentina. Defendant 

Olson is a citizen of Argentina and the United States domiciled in Argentina. 

PARTIES

12. At all times material hereto, Defendant AIRBNB, INC. is a for-profit Delaware 

corporation with its corporation headquarters in San Francisco, California, and doing business in 

every of the United States, including Illinois and throughout the world including Argentina; and at 

all times relevant hereto:

a) advertised, promoted, and rented real properties located in Buenos Aires, 

Argentina, throughout the United States, and the world;
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b) authored, publicly published and sent advertisements, information and 

emails that promoted primarily short-term rental properties including the Property to the public at 

large and recipients in Illinois, the United States and in Argentina; and

c) promoted its dedication to the safety of its property rentals.

13. Defendant AIRBNB ACTION, LLC is licensed to do and does business in Illinois, 

and is wholly owned by its sole shareholder AIRBNB, INC. 

14. Defendant AIRBNB PAYMENTS, INC. is licensed to do and does business in 

Illinois, and is wholly owned by its sole member AIRBNB, INC.

15. Defendants AIRBNB ACTION, LLC, AIRBNB PAYMENTS, INC., and AIRBNB,

INC. are hereinafter jointly referred to as “AIRBNB.”

16. At all times material hereto, Defendant Farm Club is advertised by Defendants,

including AIRBNB, as a gated community homesite with security guards located just outside 

Buenos Aires, Argentina in which, through AIRBNB, its homesite owners as the “Hosts” globally 

market, promote, and rent the homesite as a vacation rental unit. 

17. Olson is a citizen of Argentina and the United States and domiciled in Argentina. 

Fernandez is a citizen of Argentina. Fernandez and Olson are residents of Argentina. At all times 

material hereto, Defendants Fernandez and Olson were owners and AIRBNB Hosts of the Farm 

House within the Farm Club in which as the “Hosts”, through AIRBNB globally marketed, 

promoted, and rented the Farm Club as a vacation rental unit, and did rent the Farm Club to Allyson.

18. Britton is citizen of Cook County, Illinois, United States of America, a resident of 

Buenos Aires, Argentina where she attends school, and is the wife of Christian.

19. Christian is a citizen and resident of Buenos Aires, Argentina and is the husband of 

Britton. 
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20. Benjamin is a citizen and resident of Benton County, Arkansas, United States of 

America, the husband of Allyson and the father of Toddler Janie Doe.

21. Allyson, individually and as mother and next friend of Toddler Janie Doe, is a 

resident of Benton County, Arkansas, United States of America.

22. Plaintiffs are informed and believe that, and therefore allege, that at all times herein, 

Defendants, and each of them, were principals, agents, servants, employees, and/or joint venturers 

or acting in concert, and that each of them when acting as a principal were negligent in the selection, 

hiring, training, control, and supervision of each and every other defendant as agent, servant, 

employee and/or joint venturer.

23. At some or all relevant times herein, each Defendant was the agent of each other, 

acting within the scope of such agency, and ratified the conduct of the other Defendants, with active 

or constructive knowledge of such conduct.

Background and Overview of Defendant, AIRBNB Operations 

24. AIRBNB launched its business operation in 2009 and has grown to service 

approximately six million travelers per year by advertising, promoting, listing, and renting 

approximately 800,000 properties owned by third parties in approximately 100,000 cities all over 

the world. Per Defendant, AIRBNB, there are nearly 6 million listings in 191 countries made 

available through these services. 

25. Defendant, AIRBNB, operates as a brokerage marketplace that coordinates for 

property owners called “Hosts” their properties or spare rooms or units available for rent to 

customers called “Guests”. 

26. Defendant, AIRBNB, earns a percentage commission of every booking.
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27. Defendant, AIRBNB, solicits information from hosts and guests and combines that 

information with AIRBNB-created content to generate a listing in a standardized AIRBNB format 

developed by AIRBNB and governed by AIRBNB's Content Policy to promote and advertise and 

list properties based on search criteria including, as here, such distinctions as whether the property 

provides from a shared room to an entire house, to having a swimming pool, to having a washing 

machine and, as here, that the property is located in a “gated community.” There are photos of the 

property, the hosts/guests, and full map listing of the community entry gate and the house location. 

28. Once a prospective Guest requests a booking, AIRBNB collects an advance payment 

or rent on behalf of the owner/Host for the entire duration of the lease, including a security deposit.

29. AIRBNB advertises,

Trust & Safety

On any given night, 2 million people stay in homes on AIRBNB in 

100,000 cities all over the world. There are more than 6 million 

listings in 191 countries to choose from —that’s more than the top 

five hotel chains combined.

Your safety is our priority

What makes all of that possible? Trust.

Safety by design

AIRBNB is designed with safety—both online and off—in mind.

See, https://www.AIRBNB.com/trust.

30. AIRBNB holds itself out as “a trusted community marketplace” and in its 

advertising uses the words “safety”, “trust”, “home” and “trusted community” repeatedly on its 

website expecting customers to “trust” that “safety” measures actually exist and to create a false 

sense of security, but does not disclose whether or not it and its Hosts actually engage in safety 

measures such as background checks on Hosts, gated communities, community security, 

community trust and/or safety. Here, all Defendants, including AIRBNB, created a heightened 
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sense of security and safety by advertising that the Farm House was located within a gated 

community 

31. Just a few days before the events described herein, AIRBNB published the following 

article about a tragic California incident in an AIRBNB rental:

In The Business Of Trust

By AIRBNB · November 6, 2019

Company, Policy

Earlier today, AIRBNB Co-Founder, CEO and Head of Community, 

Brian Chesky, shared the following email with global employees.

Subject: In the business of trust

Hey team,

AIRBNB is a business fueled by trust. When we started AIRBNB in 

2008, people said it would never work. “Strangers will never trust 

one another,” they said. But we believed that people are 

fundamentally good, and that we could design a system for strangers 

to trust one another. Our real innovation is not allowing people to 

book a home; it’s designing a framework to allow millions of people 

to trust one another. Trust is the real energy source that drives 

AIRBNB and has enabled us to scale our platform to 191 countries 

and to more than 600 million members.

But recently, events by bad actors on our platform took 

advantage of that trust, including at a home in Orinda, 

California. We intend to do everything possible to learn from 

these incidents when they occur.

People need to feel like they can trust our community, and 

that they can trust AIRBNB when something does go wrong. Today, 

we are making the most significant steps in designing trust on 

our platform since our original design in 2008. Our update 

entails four solutions.

32. AIRBNB advertises and represents that its Trust and Safety department has offices 

in various cities such as San Francisco, Portland, Dublin and Singapore, and that it includes 24/7 

response agents, data scientists, product managers, crisis managers, and victim-advocacy 

specialists, along with privacy, cybersecurity, insurance, and fraud experts, among others. Here, 

not one 24/7 response agent, data scientist, product manager, crisis manager, victim-advocacy 
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specialist, or privacy, cybersecurity, and fraud expert contacted Plaintiffs, despite police reports 

having been filed. 

33. AIRBNB also represents that it conducts risk scoring of each AIRBNB reservation

and screens all hosts and guests against regulatory, terrorist, and sanctions watch lists.

https://news.AIRBNB.com/in-the-business-of-trust/.

34. AIRBNB’s promotion of Argentina rentals equally represents and includes a link 

for Trust and Safety. See, https://www.AIRBNB.com/s/Argentina.

35. While there is generally no duty to protect others from the criminal activity of third 

persons, when a duty to protect others against such criminal conduct has been assumed, liability 

may be created by the negligent breach of that duty.

a) Dean Prosser, in examining responsibility for intentional torts, explains 

situations which may give rise to liability. In his treatise he writes:

There are, however, other situations, in which either a special 

responsibility resting upon the defendant for the protection of the 

plaintiff, or an especial temptation and opportunity for criminal 

misconduct brought about by the defendant, will call upon him to 

take precautions against it. The responsibility for protection may 

arise out of a contract, by which the defendant has agreed to 

provide it; or it may be founded upon some relation existing 

between the parties, such as carrier and passenger, innkeeper and 

guest, invitor and business visitor, school and pupil, employer and 

employee, landlord and tenant, and no doubt others. The carrier, for 

example, may be required to protect its passengers from third persons 

who have threatened them with violence, or are drunk or 

quarrelsome, or to guard or warn them against external attack or look 

after its switches in a neighborhood which is known to be frequented 

by criminal characters. Another possibility is that the defendant's 

special responsibility may arise because he is in a position to 

control the dangerous person, or is in some other unique position 

to prevent the harm, and so may be held to have an obligation to 

exercise reasonable care to do so. (Emphasis supplied).

Prosser and Keeton on Torts, Sec. 33, p. 201–203 (West). 
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b) AIRBNB’s business involves sending its innkeeper business invitee Guests 

directly into premises owned and controlled by persons unknown to the Guests, thus Guests can 

only rely upon ARIBNB’s representations of trust and safety, a cornerstone of its business. 

c) For this service AIRBNB is compensated and earns profits. 

d) AIRBNB's duty in these situations is to exercise reasonable care and due 

diligence of an innkeeper with respect to those premises which it promotes and represents on its 

website

e) Here, AIRBNB represented that the subject property had an even higher 

level of security and safety in that it is in a gated community, that there is a security gate at the 

entrance, and that there is monitoring throughout the rental neighborhood. 

f) AIRBNB has recognized these duties and made express representations 

about “Trust and Safety” to prevent harm to its Member customers and to induce it Member 

customers to rent real estate based upon a sense of Trust and Safety. 

36. As part of its business strategy to earn profits from both Hosts and Guests, 

Defendant, AIRBNB, expressly advises and represents to consumers:

a) that “Trust & Safety” and “Your safety is our priority,” see 

https://www.AIRBNB.com/trust;

b) that Defendant, AIRBNB, provides “Safety by design” and that “AIRBNB

is designed with safety—both online and off—in mind,” see https://www.AIRBNB.com/trust;

c) that Defendant, AIRBNB, provides “Risk scoring” and that “Every 

AIRBNB reservation is scored for risk before it’s confirmed. We use predictive analytics and 

machine learning to instantly evaluate hundreds of signals that help us flag and investigate 

suspicious activity before it happens,” see https://www.AIRBNB.com;
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d) that Defendant, AIRBNB, provides “Watchlist & background checks” 

and “globally we run hosts and guests against regulatory, terrorist, and sanctions watchlists”

and “we also conduct background checks,” see https://www.AIRBNB.com/trust];

e) that “...[E]very traveler has our global community to rely on. If they want 

to see what previous guests have thought about a potential host or home, all they need to do is check 

the ratings and reviews. Guests and hosts publicly review each other, and only after the stay is 

complete, so the feedback is informed and real”;

f) that “AIRBNB is committed to earning the trust and ensuring the safety 

and security of its global community”;

g) that “AIRBNB's commitment to the safety and security of guests and 

hosts includes a global team of safety and security experts and a full range of safety practices 

including reviews, insurance, a host guarantee, and 24/7 global response and assistance”;

h) that “At the foundation of that commitment is AIRBNB’s robust Trust 

and Safety team, which is comprised of a range of 24/7 response agents, engineers, data 

scientists, product managers, designers, law-enforcement liaisons, crisis managers, and 

victim-advocacy specialists. That’s in addition to the company’s deep bench of experts in 

policy, privacy, cyber security, insurance, and fraud issues;”

i) that Defendant, AIRBNB, presents Nick Shapiro to the consuming public

as the “Global Head of Trust and Risk Management at AIRBNB”. Promotional materials 

generated by Defendant, AIRBNB, provide that “Shapiro previously served as the Deputy Chief 

of Staff of the CIA and Senior Advisor to former CIA Director John Brennan. He was also 

on the National Security Council staff and served as a White House homeland security and 

counter terrorism aide to President Obama;”
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j) that Defendant, AIRBNB, and Shapiro “...work day in and day out to 

mitigate...risk” and “build a safe and trusted environment for travelers.”;

k) that Defendant, AIRBNB, maintains that “First, safety is fundamental. 

...Next, we need to maximize transparency so that travelers know exactly what they’re 

getting.... Finally, we need our community to know they are not alone—no matter what happens—

we have a dedicated team standing by 24/7 to help resolve any issues that might arise.... [W]ith 

AIRBNB, they are safe....”;

l) In an interview with Bloomberg News, Mr. Shapiro expressly stated that:

(i) while consumers are experiencing “a crisis of distrust” in mainstream 

institutions, 

(ii) “they’re [consumers are] trusting each other more” and that “AIRBNB

was designed specifically...to leverage that new phenomenon....”

(https://www.youtube.com/watch?v=b5_vknirzSw);

m) Defendant, AIRBNB, maintains “Global hospitality standards” and requires 

that “All hosts must maintain a minimum rating and our hospitality standards to be on AIRBNB”.

https://www.AIRBNB.com];

37. Defendant, AIRBNB, processes all payments that comprise the listing, renting, 

booking, and payment for the properties.

38. Defendant, AIRBNB, sets the price of listings with a “Smart Pricing” algorithm that 

automatically adjusts prices to match demand.

39. Defendant, AIRBNB, keeps the property location “confidential until a booking 

is confirmed” and then Defendant, AIRBNB, itself discloses the address to the guest, thus 

preventing the guest from performing his/her own due diligence and investigation.
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40. Defendant, AIRBNB, actively conceals the full identities of owner “Hosts.”

41. Defendant, AIRBNB, does NOT warn “guests” of all negative circumstances 

and incidents that it becomes aware of by third-party reporting.

This AIRBNB Reservation

42. Defendant, the Farm Club, is a multi-homesite gated community.

43. The Farm House and AIRBNB expressly promote that the location has qualified 

security guards at the entry gate who monitor the property in security vehicles. The community’s 

roads even have speed limits. 

44. Plaintiffs Britton and Allyson are biological sisters.

45. Britton and Christian became husband and wife on November 14, 2019 in Buenos 

Aires, Argentina (the “Wedding”). Benjamin, Allyson and Toddler Janie Doe attended the 

Wedding.

46. Thereafter, Allyson, through AIRBNB, made a reservation to rent the Farm House 

at the Club on November 21, 2019 for herself as Guest and the other Plaintiffs as business invitees,

albeit only Allyson executed the AIRBNB agreement. AIRBNB knew the identities of all Plaintiffs

as AIRBNB required the passport numbers of all Plaintiffs in advance.

47. AIRBNB advertised the Farm House as follows: 

One hour from Buenos Aires, on 5 acres, housing 6 guests, 4 bedrooms, 7 

beds, 2.5 baths, private pool, WIFI and the television, Netflix, indoor 

stairwell slide, one-of-a-kind finishing details and pieces, hosted by 

Lindsay with a 100% 5-star location and experience rating. The 

neighborhood, Puerto Panal, has a large community pool, restaurant walking 

and riding paths, polo field, tennis courts, access to the river, “tons of tons 

of privacy and open views. (O)ur property is within a gated farm club. 

There is security gate at the entrance and monitoring throughout the 

neighborhood. The streets have speed monitoring and infractions will occur 

fines for speeds over 30 km per hour. If you plan to have day visitors, we 

allow up to 4 visitors with prior approval. We will need the names and 

document numbers of each person in your group (including visitors) to 
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allow them access into to the neighborhood. The neighborhood also 

requires the renter to sign a rental contract/reglamento de convivencia before 

arrival. Our neighborhood requires that all renters sign a rental 

contract/ reglamento de Convivencia prior to rental date and bring the 

signed copy at check-in to the entrance of the neighborhood. Renters 

must also provide names and DNI of every person in their party.

(Emphasis supplied).

48. The AIRBNB posting included the following Farm House photos: 

Photo A

Photo B
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Photo C

Photo D

49. The Plaintiffs traveled to the Farm Club via hired vehicle (“Cab”), the roof and trunk 

loaded with luggage and supplies.

50. Upon entering the Farm Club’s entry drive, the drive forked right and left. They 

were directed to the left drive up and a lowered striped gate in between two guard houses.

51. The Cab stopped at the lowered gate. Two security guards (“Guards”) were present, 

one inside the left guard house and one outside between the left guard house and the Cab. On 
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information and belief, Plaintiffs are informed and belive that the security company and the Guards 

were employees or independent contractors and the agents of Defendants and each of them. 

52. The outside guard approached and requested and noted the driver’s personal and 

vehicle identification. AIRBNB and Hosts require passport names, photos and numbers several 

days before arriving at a rental. The security guards required identification at the gate. Plaintiffs’ 

identities were provided at the gate. The Guard(s) did not otherwise require presentation of 

passports or other personal identification. The Guards were aware that most Plaintiffs were from 

the U.S. Defendants and each of them failed to assure the security of their identities vis-à-vis the 

security company and the Guards and from being disseminated to the Assailants.

53. AIRBNB rental contract stated no guns or weapons. The Guards made no inquiry 

about guns or weapons.

54. The AIRBNB rental form states that there would be keys. The Guards provided no 

Farm House keys or other entry devices. Plaintiffs found the Farm House sliding doors open and 

no keys.

55. The only publicly known and available entry into the gated community is through 

the guarded main gate.

56. In addition to the gated community and the Guards, the Farm House had security 

cameras providing Plaintiffs an additional [false] sense of security. After the hostage taking, the 

Hosts told Plaintiffs that the Farm House security cameras were fake, but that they were thereafter 

going to install actual fully operational high-tech security system.

57. Near midnight, Toddler Janie Doe was asleep. Plaintiffs Britton, Christian and 

Allyson were in the family room depicted in Photos B and C having casual conversation. Benjamin 

was in the kitchen making snacks for the group.
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58. As Benjamin walked out of the kitchen and down the hall to the family room, he 

came face-to-face with four men wearing black clothes and their faces fully masked (the 

“Assailants”). The Assailants carried guns and knives. Benjamin tried to order them to stop. They 

ignored him and pushed him into the family room with Britton, Christian and Allyson.

59. The Assailants seemed to know the lay-out. They knew where the light switches 

were and turned off the lights.

60. Two of the Assailants, while pointing guns at her, aggressively took Allyson by the 

arm into one of the back bedrooms. There, she offered them her wallet, her passport, her computer, 

and anything she could find of value. They took the cash in her wallet and left everything else. They 

aggressively shoved Allyson into the main room and onto the floor with Britton and Christian.

61. Allyson, Britton, Christian’s arms were tightly yanked and pulled behind their 

backs. Their arms and hands were bound together at the wrists by copper wire tightly secured, 

physically brutalizing them. The Assailants pulled at the bottom of Britton and Allyson’s pant legs

causing them to believe they would be sexually assaulted. Britton screamed. The Assailants 

removed Britton’s socks and stuffed them into her mouth. The Assailants ripped some fabric and 

tightly covered and bound Allyson’s mouth, tying the fabric in a knot behind her head. The 

Assailants, a second time, tightly bound their wrists inflicting further torture. 

62. In the meantime, two of the Assailants took Benjamin to one of the bedrooms. 

Benjamin removed his and Allyson’s passports, cell phones computers and the Argentine money 

that they had from their bags and offered them to the Assailants. They continued to demand more 

money and insisted that Benjamin was lying and hiding additional U.S. dollars. For about one hour

or more, the Assailants threatened and tormented Benjamin with loaded guns pointed at his head. 

They showed Benjamin bullets in a gun. One Assailant hit Benjamin on the head with his gun 
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handle causing an open headwound with blood running down Benjamin’s face and neck. They 

Assailants placed bolt cutters on a finger and threatened to cut Benjamin’s finger off multiple times 

if he did not give them U.S. dollars. The other Plaintiffs, including Allyson (Benjamin’s wife),

heard everything from the living room. The Assailants kept demanding U.S. dollars, took other 

personal property, and destroyed cell phones.

63. A bloodied and wounded Benjamin was brought back to the living room floor and 

laid on the floor next to the others. Blood from Benjamin’s head pooled on the floor. They ripped 

a piece of cloth and tied a gag around Benjamin’s neck and in his mouth. One of the Assailants put 

the point of his knife into Benjamin’s side and continued to demand U.S. dollars. They again 

threatened to cut off a finger with bolt cutters. Another Assailant painfully removed Benjamin’s 

wedding ring from his swollen finger while his hands were tied behind his back.

64. In the room where Toddler Janie Doe lay sleeping, Allyson kept a baby monitor 

which they could clearly hear in the main room. They could hear what was going on in the back of 

the house, and specifically in Toddler Janie Doe’s room. The Assailants upended the entire house, 

frequently moving into and out of the main room for long periods of time and could hear crashing

and banging including in Toddler Janie Doe’s bedroom brutally frightening and tormenting Toddler 

Janie Doe’s parents.

65. All Plaintiffs lay on the main room floor and were tormented for many excruciating 

and physically and emotionally painful hours, gagged and with arms and hands tightly bound 

behind their backs and arms and hands. For hours they could not go to the bathroom and soiled 

themselves. They could not move their arms or even stretch their legs and bodies. They were in fear 

of severe injury and death. 
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66. During the Assailants’ terrifying taunting and threats they also mocked Plaintiffs. 

In Spanish they told Plaintiffs, “You guys are fucked, the security guards sold you out.” They said, 

“We are going to go to neighbor next.” (Later, the guards were interrogated by the police and 

arrested. The police confirmed to Britton that the guards were in fact in on it).

67. Allyson and Benjamin were in desperate fear for their daughter’s safety, and 

repeatedly asked about Toddler Janie Doe. The Assailants responded to the Toddler’s mother 

Allyson that they were going to “dump her [the Toddler] in a field.” Christian and Britton in Spanish 

cried out and begged for their niece Toddler’s safety.

68. After about three hours, the Assailants had left the living room. It was still dark. 

There was no noise. Plaintiffs all remained on the floor in silence. Then, hearing no one, Christian 

called out in Spanish, “Anybody still there?” Christian painfully stretched and loosened the wires 

on his wrists and freed himself. He untied Britton who had an injured wrist, who in turn untied 

Allyson who also complained of an injured wrist and right thumb and forefinger, who in turn 

crawled and untied Benjamin. Because they did not know whether the Assailants were still present,

they kept their hands behind their backs and remained silent.

69. Christian found his cell phone, unbroken. He quietly called 911. He informed the 

officer that they were being held hostage; that he thought the Assailants still may be on the site; 

and that they had no way of escape. The officer said they would call back but did not.

70. Christian called 410 for an “immediate healthcare ambulance.” Britton used 

Christian’s phone to call the US Embassy in Buenos Aires. She explained the situation and begged 

to be rescued. She was told they could not send a US Marine unit.

71. Christian called a different police department. They took over an hour to arrive. 
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72. In the interim, Christian called the cab driver that delivered them to the property. 

He was a friend. He lived about one hour away but immediately got in the cab to help.

73. Plaintiffs fear turned to hope when a security car with a roof light drove close to the 

Farm House building. The car stopped and sat there for a while with a flashing light on. They were 

not sure who it was. A security guard exited the vehicle, approached the Farm House, and peeked 

into the sliding door windows (even though AIRBNB and Hosts promise safety and privacy to its 

guests). No one, including security guards, had permission to, nor would have reason to, look into 

the windows and doors. It was dark inside. The security guard got back into his car and left.

74. Briton could not feel her hands. Her right hand was in great pain. She would up with 

nerve damage. Her injury later caused her to be unable to work and also to attend medical school. 

75. Allyson could not feel her hands, and her thumb seemed to be dangling. She had 

nerve damage. Her injury later caused her to be unable to work and care for her toddler daughter.

76. Benjamin was dazed and suffering from his head wound. He would later require 

stiches and has a permanent scar and loss of hair at the scar. 

77. Plaintiffs decided they had to try and escape. Britton wanted to go out into the bush. 

Allyson wanted to make a run to the nearest neighbor whom she saw walking his dog earlier in the 

day. Allyson quickly awakened her daughter and put on her whatever warm clothes she could find. 

78. They all prepared to exit and run. Britton and Christian were first to exist and lead 

the way. As they did, they were stunned and panicked in the dark by people pointing guns at them

and yelling to get down on the ground. It was the police. They slowly approached and realized they 

were the victims. Eventually, at the same time the cab driver arrived, an ambulance with 

paramedics, and more police and a detective arrived. 

79. Plaintiffs were consoled. Benjamin’s head wound was minimally treated. 
21

80. The security guards were brought into the Farm House which upset the Plaintiffs. 

Britton saw one of the security guards turn his head while whispering into a cell phone. Britton 

yelled at the police to take the security guard’s phone away because the Assailants said they were

accomplices. The police confiscated the security guards’ phones.

81. A well-dressed man also arrived. He said he was a representative of the property

community. He was overly apologetic to the Plaintiffs and begged them to not make a police report. 

82. Plaintiffs eventually went to two Buenos Aires hospitals for treatment, Benjamin for 

his head wound. One day later, one of the AIRBNB property Hosts delivered Plaintiffs remaining 

personal belongings to Christian. The Host said the security guards were fired and arrested. He 

apologized. That is when he also informed Christian that the security cameras were fake.

83. This Court has jurisdiction over the subject matter of this claim for damages in an 

amount in excess of $75,000, exclusive of all costs, interest and attorneys’ fees.

COUNT I

BRITTON ESPOSITO - NEGLIGENCE

AGAINST DEFENDANTS FERNANDEZ AND OLSON

84. Plaintiff Britton Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 84 hereof. 

85. At all times material hereto, Defendants Fernandez and Olson owed a duty to 

maintain its premises, in a reasonably safe condition, and to take reasonable care for the safety of 

Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties and 

employees and agents, such as the security guards, to protect the Plaintiffs from being harmed by 

such persons, and further had a duty to implement policies and procedures to protect guests such as

Plaintiffs.
22

86. At all times material hereto, Defendants Fernandez and Olson knew or should have 

known of the potential danger in facilitating un-supervised access to renters in a private setting.

87. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Fernandez and Olson, conducted no criminal background checks about its security 

company and security guard agents and/or any background checks that were performed were 

patently insufficient.

88. Defendants Fernandez and Olson knew or should have known there were no keys 

for the Farm House, and that the security cameras were fake.

89. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Fernandez and Olson as employees, independent 

contractors or agents in allowing the Assailants access to the Farm Club and the Farm House.

90. Defendants Fernandez and Olson received direct benefits, including potential or 

indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable care for 

the protection of Plaintiffs to permit only those employees, independent contractors or agents of 

Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; failed to 

warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

91. As a direct and proximate result of Defendants Fernandez and Olson breach of duties 

owed to Plaintiffs described herein, Britton suffered physical pain and suffering, emotional distress, 

loss of personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Britton Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendants Fernandez and Olson, plus costs 

and a trial by jury on all issues so triable.
23

COUNT II

BRITTON ESPOSITO - NEGLIGENCE

AGAINST DEFENDANT FARM CLUB AND/OR ITS ASSOCIATION

92. Plaintiff Britton Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 92 hereof.

93. At all times material hereto, Defendant Farm Club owed a duty to maintain its 

premises, in a reasonably safe condition, and to take reasonable care for the safety of Plaintiffs and 

protect them from reasonably foreseeable criminal conduct by third parties and employees and 

agents, such as the security guards, to protect the Plaintiffs from being harmed by such persons, 

and further had a duty to implement policies and procedures to protect guests such as Plaintiffs.

94. At all times material hereto, Defendant Farm Club knew or should have known of 

the potential danger in facilitating un-supervised access to renters in a private setting.

95. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendant Farm Club, conducted no criminal background checks about its security company and 

security guard agents and/or any background checks that were performed were patently insufficient.

96. Defendant Farm Club knew or should have known there were no keys for the Farm 

House, and that the security cameras were fake.

97. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendant Farm Club as employees, independent contractors 

or agents in allowing the Assailants access to the Farm Club and the Farm House.

98. Defendant Farm Club received direct benefits, including potential or indirect 

benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable care for the 

protection of Plaintiffs to permit only those employees, independent contractors or agents of 
24

Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; failed to 

warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

99. As a direct and proximate result of Defendant Farm Club’s breach of duties owed to 

Plaintiffs described herein, Britton suffered physical pain and suffering, emotional distress, loss of 

personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Britton Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant Farm Club, plus costs and a trial 

by jury on all issues so triable

COUNT III

BRITTON ESPOSITO

VICARIOUS LIABILITY OF

THE FARM CLUB AND/OR ITS ASSOCIATION, AND

FERNANDEZ AND OLSON

100. Plaintiff Britton Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 100 hereof. 

101. At all times material hereto, Defendants Farm Club, Fernandez and Olson owed a 

duty to maintain their premises, in a reasonably safe condition, and to take reasonable care for the 

safety of Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties 

and employees and agents, such as the security guards, to protect the Plaintiffs from being harmed 

by such persons, and further had a duty to implement policies and procedures to protect guests such 

as Plaintiffs.

102. At all times material hereto, Defendants Farm Club, Fernandez and Olson knew or 

should have known of the potential danger in facilitating un-supervised access to renters in a private 

setting.
25

103. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Farm Club, Fernandez and Olson conducted no criminal background checks about their

security company and security guard agents and/or any background checks that were performed 

were patently insufficient.

104. Defendants Farm Club, Fernandez and Olson knew or should have known there were 

no keys for the Farm House, and that the security cameras were fake.

105. Defendants Farm Club, Fernandez and Olson rare vicariously liable for the conduct 

of the security company and its security guards as its employees or independent contractor and 

agents in that they had the right to control and direct the security company and its security guards 

in their duties. 

106. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Farm Club, Fernandez and Olson as employees, 

independent contractors or agents in allowing the Assailants access to the Farm Club and the Farm 

House. 

107. Defendants Farm Club, Fernandez and Olson received direct benefits, including 

potential or indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable 

care for the protection of Plaintiffs to permit only those employees, independent contractors or 

agents of Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; 

failed to warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

108. As a direct and proximate result of Defendants Farm Club, Fernandez and Olson

breach of duties owed to Plaintiffs described herein, Britton suffered physical pain and suffering, 

emotional distress, loss of personal property, and other damages an amount in excess of $75,000.
26

WHEREFORE, Plaintiff Britton Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendants Farm Club, Fernandez and 

Olson, plus costs and a trial by jury on all issues so triable.

COUNT IV

BRITTON ESPOSITO

NEGLIGENT HIRING/RETENTION

AGAINST THE FARM CLUB AND/OR ITS ASSOCIATION, AND

FERNANDEZ AND OLSON

109. Plaintiff Britton Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 109 hereof. 

110. At all times material hereto, Defendants Farm Club, Fernandez and Olson owed a 

duty to maintain their premises, in a reasonably safe condition, and to take reasonable care for the 

safety of Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties 

and employees and agents, such as the security guards, to protect the Plaintiffs from being harmed 

by such persons, and further had a duty to implement policies and procedures to protect guests such 

as Plaintiffs.

111. At all times material hereto, Defendants Farm Club, Fernandez and Olson knew or 

should have known of the potential danger in facilitating un-supervised access to renters in a private 

setting.

112. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Farm Club, Fernandez and Olson, conducted no criminal background checks about their

security company and security guard agents and/or any background checks that were performed 

were patently insufficient.

113. Defendants Farm Club, Fernandez and Olson knew or should have known there were 

no keys for the Farm House, and that the security cameras were fake.
27

114. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Farm Club, Fernandez and Olson as employees, 

independent contractors or agents in allowing the Assailants access to the Farm Club and the Farm 

House. 

115. Defendants Farm Club, Fernandez and Olson received direct benefits, including 

potential or indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable 

care for the protection of Plaintiffs to permit only those employees, independent contractors or 

agents of Defendants Farm Club, Fernandez and Olson who, so far as can be reasonably ascertained, 

pose no threat to such guests; failed to warn Plaintiffs of such danger; and, failed to protect Plaintiffs 

from such danger.

116. By virtue of its business and legal relationships with the Plaintiffs, Defendants Farm 

Club, Fernandez and Olson owed Plaintiffs a duty to not hire and/or retain the dishonest and 

negligent security company and the security guards.

117. Plaintiffs were informed and believe, and on that basis allege, that at no time during

the periods of time alleged did Defendants Farm Club, Fernandez and Olson have in place a system

or procedure to reasonably investigate, supervise and/or monitor staff and official resort personnel

to prevent criminal acts against guests, nor did they implement a system or procedure to oversee or 

monitor conduct toward guests.

118. Defendants Farm Club, Fernandez and Olson were or should have been aware and 

understood how vulnerable guests were to violence through the negligence of security guards and 

other persons of authority within the control of Defendants.

119. Plaintiffs were informed, and believe, and on that basis allege, that the Defendants 

Farm Club, Fernandez and Olson were put on notice that the security company and the security 
28

guards were unhappy losing their contract and jobs with the Defendants Farm Club, Fernandez and 

Olson because the Defendants Farm Club, Fernandez and Olson had been dissatisfied with the 

ability and performance of the security company and the security guards, and should have foreseen

that the security company and the security guards were engaging in, or would engage in dangerous 

and harmful acts against Plaintiffs under the cloak of their authority, confidence, and trust, 

bestowed upon them through Defendants Farm Club, Fernandez and Olson.

120. Defendants Farm Club, Fernandez and Olson failed to use reasonable care to 

supervise or monitor the security company and the security guards to ensure the safety of guests at 

the Farm House.

121. Defendants Farm Club, Fernandez and Olson’s conduct was a breach of their duty 

to Plaintiffs;

122. As a direct and proximate result of Defendants Farm Club, Fernandez and Olson’s 

breach of duties owed to Plaintiffs described herein, Britton suffered physical pain and suffering, 

emotional distress, loss of personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Britton Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendants Farm Club, Fernandez and 

Olson, plus costs and a trial by jury on all issues so triable.

COUNT V

BRITTON ESPOSITO

NEGLIGENCE AGAINST AIRBNB

123. Plaintiff Britton Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 123 hereof.

124. At all times material hereto, Defendant, AIRBNB, assumed and/or owed a duty to

take reasonable care for the safety of its customers, including Plaintiffs and to protect them from 
29

reasonably foreseeable negligent and/or criminal conduct by third parties and employees and 

agents, including the Assailants, the security company and the security guards, and to provide 

sufficient warning of the risk of harm, and to protect the Plaintiffs from being harmed by such 

persons.

125. Defendant, AIRBNB, knew or should have known that there is an industry 

recognized increased danger for United Sates citizens to be susceptible to crime in secluded and 

unfamiliar settings where opportunity is provided for predators to commit crimes against, and/or 

harm to, their persons and property. 

126. At the time of the subject matter, Defendant, AIRBNB, failed to assure or 

negligently attempted to investigate safety of the Defendants Farm Club, Fernandez and Olson, the 

security company and the security guards, which was patently insufficient.

127. Plaintiffs were vulnerable to the security company and the security guards by virtue 

of their apparent and/or actual authority of the Defendants Farm Club, Fernandez and Olson to 

control access to the Farm Club, and to provide Farm House keys and assure that the security 

cameras worked so as to not provide a false sense of security and safety.

128. Defendant, AIRBNB, received some benefit, including potential or indirect benefit, 

by its rental to Allyson, and there exists a duty to exercise reasonable care for the protection of 

guests to permit to enter the Farm Club only those persons who, so far as can be reasonably 

ascertained, would pose no threat to such guests. Defendant, AIRBNB, failed to warn Plaintiffs of 

such danger and failed to protect Plaintiffs from such danger.

129. Defendant, AIRBNB, breached the above referenced duties owed to Plaintiffs, and 

as result thereof, Plaintiffs were falsely imprisoned, assaulted and otherwise traumatized.
30

130. As a direct and proximate result of Defendant AIRBNB’s breach of duties owed to 

Plaintiffs described herein, Britton suffered physical pain and suffering, emotional distress, loss of 

personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Britton Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant AIRBNB, plus costs and a trial 

by jury on all issues so triable.

COUNT VI

BRITTON ESPOSITO

VICARIOUS LIABILITY OF AIRBNB

131. Plaintiff Britton Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 131 hereof.

132. At all times material, Defendant AIRBNB contracted with Defendants Farm Club, 

Fernandez and/or Olson, which in turn subcontracted with the security company and the security 

guards, and/or otherwise vested them with the apparent or actual authority of Defendant, AIRBNB. 

Defendants Farm Club, Fernandez and/or Olson, which in turn subcontracted with the security 

company and the security guards, was acting under Defendant AIRBNB’s authority, direct 

supervision, employment and/or control when the wrongful and negligent acts described herein

were committed. Defendants Farm Club, Fernandez and/or Olson, which in turn subcontracted with 

the security company and the security guards, engaged in this conduct while acting in the course 

and scope of their employment and/or apparent agency and/or actual agency with Defendant 

AIRBNB and/or accomplished the described conduct by virtue of their apparent authority.

133. Defendant, AIRBNB, granted Defendants Farm Club, Fernandez and/or Olson

authority to perform as an agent within the AIRBNB rented Farm House and otherwise held 

Defendants Farm Club, Fernandez and/or Olson out to the community as a fit and competent agent 
31

of the resort. Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards committed the acts alleged within the apparent authority arising from the agency. 

Said conduct was undertaken in the course and scope of Defendants Farm Club, Fernandez and/or 

Olson and their security company and security guards’ employment and/or agency regarding rental 

of the Farm House and/or was ratified by Defendant, AIRBNB.

134. Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards were acting at least in part to serve the interests of Defendant, AIRBNB, when 

Defendants Farm Club, Fernandez and/or Olson and their security company and security guards 

committed the negligent acts described herein. Specifically, Defendants Farm Club, Fernandez 

and/or Olson and their security company and security guards were acting as an agent, as well as 

using the trust, power and authority of the position granted, while engaging with Plaintiffs.

Simultaneously, Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards used that same power and authority to gain Plaintiffs’ confidence and promise them 

Safety and Trust.

135. The harm to Plaintiffs caused by Defendants Farm Club, Fernandez and/or Olson 

and their security company and security guards was a foreseeable and well-known hazard of the 

industry as evidenced by AIRBNB’s need to promise Safety and Trust.

136. Because of the Defendants Farm Club, Fernandez and/or Olson and their security 

company and security guards negligence and tortious conduct during their agency relationship with 

Defendant AIRBNB while within the course and scope of their agency and employment, Defendant

AIRBNB under the law of vicarious liability, including the doctrine of respondeat superior.
32

137. As a direct and proximate result of Defendant AIRBNB’s breach of duties owed to 

Plaintiffs described herein, Britton suffered physical pain and suffering, emotional distress, loss of 

personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Britton Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant AIRBNB, plus costs and a trial 

by jury on all issues so triable.

COUNT VII

CHRISTIAN FRESNO - NEGLIGENCE

AGAINST DEFENDANTS FERNANDEZ AND OLSON

138. Plaintiff Christian Fresno re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 138 hereof. 

139. At all times material hereto, Defendants Fernandez and Olson owed a duty to 

maintain their premises, in a reasonably safe condition, and to take reasonable care for the safety 

of Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties and 

employees and agents, such as the security guards, to protect the Plaintiffs from being harmed by 

such persons, and further had a duty to implement policies and procedures to protect guests such as 

Plaintiffs.

140. At all times material hereto, Defendants Fernandez and Olson knew or should have 

known of the potential danger in facilitating un-supervised access to renters in a private setting.

141. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Fernandez and Olson, conducted no criminal background checks about their security 

company and security guard agents and/or any background checks that were performed were 

patently insufficient.
33

142. Defendants Fernandez and Olson knew or should have known there were no keys 

for the Farm House, and that the security cameras were fake.

143. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Fernandez and Olson as employees, independent 

contractors or agents in allowing the Assailants access to the Farm Club and the Farm House.

144. Defendants Fernandez and Olson received direct benefits, including potential or 

indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable care for 

the protection of Plaintiffs to permit only those employees, independent contractors or agents of 

Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; failed to 

warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

145. As a direct and proximate result of Defendants Fernandez and Olson breach of duties 

owed to Plaintiffs described herein, Christian suffered physical pain and suffering, emotional 

distress, loss of personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Christian Fresno seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendants Fernandez and Olson, plus costs 

and a trial by jury on all issues so triable.

COUNT VIII

CHRISTIAN FRESNO - NEGLIGENCE

AGAINST DEFENDANT FARM CLUB AND/OR ITS ASSOCIATION

146. Plaintiff Christian Fresno re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 146 hereof. 

147. At all times material hereto, Defendant Farm Club owed a duty to maintain its 

premises, in a reasonably safe condition, and to take reasonable care for the safety of Plaintiffs and 

protect them from reasonably foreseeable criminal conduct by third parties and employees and 
34

agents, such as the security guards, to protect the Plaintiffs from being harmed by such persons, 

and further had a duty to implement policies and procedures to protect guests such as Plaintiffs.

148. At all times material hereto, Defendant Farm Club knew or should have known of 

the potential danger in facilitating un-supervised access to renters in a private setting.

149. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendant Farm Club, conducted no criminal background checks about its security company and 

security guard agents and/or any background checks that were performed were patently insufficient.

150. Defendant Farm Club knew or should have known there were no keys for the Farm 

House, and that the security cameras were fake.

151. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendant Farm Club as employees, independent contractors 

or agents in allowing the Assailants access to the Farm Club and the Farm House.

152. Defendant Farm Club received direct benefits, including potential or indirect 

benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable care for the 

protection of Plaintiffs to permit only those employees, independent contractors or agents of 

Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; failed to 

warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

153. As a direct and proximate result of Defendant Farm Club’s breach of duties owed to 

Plaintiffs described herein, Christian suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Christian Fresno seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant Farm Club, plus costs and a trial 

by jury on all issues so triable
35

COUNT IX

CHRISTIAN FRESNO

VICARIOUS LIABILITY OF

THE FARM CLUB AND/OR ITS ASSOCIATION, AND

FERNANDEZ AND OLSON

154. Plaintiff Christian Fresno re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 154 hereof. 

155. At all times material hereto, Defendants Farm Club, Fernandez and Olson owed a 

duty to maintain their premises, in a reasonably safe condition, and to take reasonable care for the 

safety of Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties 

and employees and agents, such as the security guards, to protect the Plaintiffs from being harmed 

by such persons, and further had a duty to implement policies and procedures to protect guests such 

as Plaintiffs.

156. At all times material hereto, Defendants Farm Club, Fernandez and Olson knew or 

should have known of the potential danger in facilitating un-supervised access to renters in a private 

setting.

157. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Farm Club, Fernandez and Olson, conducted no criminal background checks about their

security company and security guard agents and/or any background checks that were performed 

were patently insufficient.

158. Defendants Farm Club, Fernandez and Olson knew or should have known there were 

no keys for the Farm House, and that the security cameras were fake.

159. Defendants Farm Club, Fernandez and Olson are vicariously liable for the conduct 

of the security company and its security guards as its employees or independent contractor and 
36

agents in that they had the right to control and direct the security company and its security guards 

in their duties. 

160. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Farm Club, Fernandez and Olson, as employees, 

independent contractors or agents in allowing the Assailants access to the Farm Club and the Farm 

House. 

161. Defendants Farm Club, Fernandez and Olson received direct benefits, including 

potential or indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable 

care for the protection of Plaintiffs to permit only those employees, independent contractors or 

agents of Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; 

failed to warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

162. As a direct and proximate result of Defendants Farm Club, Fernandez and Olson’s

breach of duties owed to Plaintiffs described herein, Christian suffered physical pain and suffering, 

emotional distress, loss of personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Christian Fresno seeks judgment for damages in excess of One 

and One Half Million Dollars ($1,500,000) against the Defendants, Farm Club, Fernandez and 

Olson, plus costs and a trial by jury on all issues so triable.

COUNT X

CHRISTIAN FRESNO

NEGLIGENT HIRING/RETENTION

AGAINST THE FARM CLUB AND/OR ITS ASSOCIATION, AND

FERNANDEZ AND OLSON

163. Plaintiff Christian Fresno re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 163 hereof. 
37

164. At all times material hereto, Defendants Farm Club, Fernandez and Olson owed a 

duty to maintain their premises, in a reasonably safe condition, and to take reasonable care for the 

safety of Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties 

and employees and agents, such as the security guards, to protect the Plaintiffs from being harmed 

by such persons, and further had a duty to implement policies and procedures to protect guests such 

as Plaintiffs.

165. At all times material hereto, Defendants Farm Club, Fernandez and Olson knew or 

should have known of the potential danger in facilitating un-supervised access to renters in a private 

setting.

166. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Farm Club, Fernandez and Olson, conducted no criminal background checks about their

security company and security guard agents and/or any background checks that were performed 

were patently insufficient.

167. Defendants Farm Club, Fernandez and Olson knew or should have known there were 

no keys for the Farm House, and that the security cameras were fake.

168. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Farm Club, Fernandez and Olson as employees, 

independent contractors or agents in allowing the Assailants access to the Farm Club and the Farm 

House. 

169. Defendants Farm Club, Fernandez and Olson received direct benefits, including 

potential or indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable 

care for the protection of Plaintiffs to permit only those employees, independent contractors or 

agents of Defendants Farm Club, Fernandez and Olson who, so far as can be reasonably ascertained, 
38

pose no threat to such guests; failed to warn Plaintiffs of such danger; and, failed to protect Plaintiffs 

from such danger.

170. By virtue of its business and legal relationships with the Plaintiffs Defendants Farm 

Club, Fernandez and Olson owed Plaintiffs a duty to not hire and/or retain the dishonest and 

negligent security company and security guards.

171. Plaintiffs were informed and believe, and on that basis allege, that at no time during 

the periods of time alleged did Defendants Farm Club, Fernandez and Olson have in place a system

or procedure to reasonably investigate, supervise and/or monitor staff and official resort personnel 

to prevent criminal acts against guests, nor did they implement a system or procedure to oversee or 

monitor conduct toward guests.

172. Defendants Farm Club, Fernandez and Olson was or should have been aware and 

understood how vulnerable guests were to violence through the negligence of security guards and 

other persons of authority within the control of Defendants.

173. Plaintiffs were informed, and believe, and on that basis allege, that the Defendants 

Farm Club, Fernandez and Olson were put on notice that the security company and the security 

guards were unhappy losing their contract and jobs with the Defendants Farm Club, Fernandez and 

Olson because the Defendants Farm Club, Fernandez and Olson had been dissatisfied with the 

ability and performance of the security company and the security guards, and should have foreseen

that the security company and the security guards were engaging in, or would engage in dangerous 

and harmful acts against Plaintiffs under the cloak of their authority, confidence, and trust, 

bestowed upon them through Defendants Farm Club, Fernandez and Olson.
39

174. Defendants Farm Club, Fernandez and Olson failed to use reasonable care to 

supervise or monitor the security company and the security guards to ensure the safety of guests at 

the Farm House.

175. Defendants Farm Club, Fernandez and Olson’s conduct was a breach of their duty 

to Plaintiffs.

176. As a direct and proximate result of Defendant Farm Club, Fernandez and Olson’s

breach of duties owed to Plaintiffs described herein, Christian suffered physical pain and suffering, 

emotional distress, loss of personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Christian Fresno seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendants Farm Club, Fernandez and 

Olson, plus costs and a trial by jury on all issues so triable.

COUNT XI

CHRISTIAN FRESNO

NEGLIGENCE AGAINST AIRBNB

177. Plaintiff Christian Fresno re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 177 hereof.

178. At all times material hereto, Defendant, AIRBNB, assumed and/or owed a duty to 

take reasonable care for the safety of its customers, including Plaintiffs and to protect them from 

reasonably foreseeable negligent and/or criminal conduct by third parties and employees and 

agents, including the Assailants, the security company and the security guards, and to provide 

sufficient warning of the risk of harm, and to protect the Plaintiffs from being harmed by such 

persons.

179. Defendant, AIRBNB, knew or should have known that there is an industry 

recognized increased danger for United Sates citizens to be susceptible to crime in secluded and 
40

unfamiliar settings where opportunity is provided for predators to commit crimes against, and/or 

harm to, their persons and property. 

180. At the time of the subject matter, Defendant, AIRBNB, failed to assure or 

negligently attempted to investigate safety of the Defendants Farm Club, Fernandez and Olson, the 

security company and the security guards which were patently inadequate.

181. Plaintiffs were vulnerable to the security company and the security guards by virtue 

of their apparent and/or actual authority of the Defendants Farm Club, Fernandez and Olson to 

control access to the Farm Club, and to provide Farm House keys and assure that the security 

cameras worked so as to not provide a false sense of security and safety.

182. Defendant, AIRBNB, received some benefit, including potential or indirect benefit, 

by its rental to Allyson, and there exists a duty to exercise reasonable care for the protection of 

guests to permit to enter the Farm Club only those persons who, so far as can be reasonably 

ascertained, would pose no threat to such guests. Defendant, AIRBNB, failed to warn Plaintiffs of 

such danger and failed to protect Plaintiffs from such danger.

183. Defendant, AIRBNB, breached the above referenced duties owed to Plaintiffs, and 

as result thereof, Plaintiffs were falsely imprisoned, assaulted and otherwise traumatized. 

184. As a direct and proximate result of Defendant AIRBNB’s breach of duties owed to 

Plaintiffs described herein, Christian suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Christian Fresno seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant AIRBNB, plus costs and a trial 

by jury on all issues so triable.
41

COUNT XII

CHRISTIAN FRESNO

VICARIOUS LIABILITY OF AIRBNB

185. Plaintiff Christian Fresno re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 185 hereof.

186. At all times material, Defendant AIRBNB contracted with Defendants Farm Club, 

Fernandez and/or Olson, which in turn subcontracted with the security company and the security 

guards, and/or otherwise vested them with the apparent or actual authority of Defendant, AIRBNB. 

Defendants Farm Club, Fernandez and/or Olson, which in turn subcontracted with the security 

company and the security guards, was acting under Defendant AIRBNB’s authority, direct 

supervision, employment and/or control when the wrongful and negligent acts described herein 

were committed. Defendants Farm Club, Fernandez and/or Olson, which in turn subcontracted with 

the security company and the security guards, engaged in this conduct while acting in the course 

and scope of their employment and/or apparent agency and/or actual agency with Defendant 

AIRBNB and/or accomplished the described conduct by virtue of their apparent authority.

187. Defendant, AIRBNB, granted Defendants Farm Club, Fernandez and/or Olson 

authority to perform as an agent within the AIRBNB rented Farm House and otherwise held 

Defendants Farm Club, Fernandez and/or Olson out to the community as a fit and competent agent 

of the resort. Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards committed the acts alleged within the apparent authority arising from the agency. 

Said conduct was undertaken in the course and scope of Defendants Farm Club, Fernandez and/or 

Olson and their security company and security guards’ employment and/or agency regarding rental 

of the Farm House and/or was ratified by Defendant, AIRBNB.
42

188. Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards were acting at least in part to serve the interests of Defendant, AIRBNB, when 

Defendants Farm Club, Fernandez and/or Olson and their security company and security guards 

committed the negligent acts described herein. Specifically, Defendants Farm Club, Fernandez 

and/or Olson and their security company and security guards were acting as an agent, as well as 

using the trust, power and authority of the position granted, while engaging with Plaintiffs. 

Simultaneously, Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards used that same power and authority to gain Plaintiffs’ confidence and promise them 

Safety and Trust.

189. The harm to Plaintiffs caused by Defendants Farm Club, Fernandez and/or Olson 

and their security company and security guards was a foreseeable and well-known hazard of the 

industry as evidenced by AIRBNB’s need to promise Safety and Trust.

190. Because of the Defendants Farm Club, Fernandez and/or Olson and their security 

company and security guards negligent and tortious conduct during their agency relationship with 

Defendant AIRBNB while within the course and scope of their agency and employment, Defendant 

AIRBNB under the law of vicarious liability, including the doctrine of respondeat superior.

191. As a direct and proximate result of Defendant AIRBNB’s breach of duties owed to 

Plaintiffs described herein, Christian suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Christian Fresno seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant AIRBNB, plus costs and a trial 

by jury on all issues so triable.
43

COUNT XIII

BENJAMIN KUTYLO - NEGLIGENCE

AGAINST DEFENDANTS FERNANDEZ AND OLSON

192. Plaintiff Benjamin Kutylo re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 192 hereof. 

193. At all times material hereto, Defendants Fernandez and Olson owed a duty to 

maintain its premises, in a reasonably safe condition, and to take reasonable care for the safety of 

Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties and 

employees and agents, such as the security guards, to protect the Plaintiffs from being harmed by 

such persons, and further had a duty to implement policies and procedures to protect guests such as 

Plaintiffs.

194. At all times material hereto, Defendants Fernandez and Olson knew or should have 

known of the potential danger in facilitating un-supervised access to renters in a private setting.

195. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Fernandez and Olson, conducted no criminal background checks about their security 

company and security guard agents and/or any background checks that were performed were

patently insufficient.

196. Defendants Fernandez and Olson knew or should have known there were no keys 

for the Farm House, and that the security cameras were fake.

197. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Fernandez and Olson as employees, independent 

contractors or agents in allowing the Assailants access to the Farm Club and the Farm House.

198. Defendants Fernandez and Olson received direct benefits, including potential or

indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable care for 
44

the protection of Plaintiffs to permit only those employees, independent contractors or agents of 

Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; failed to 

warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

199. As a direct and proximate result of Defendants Fernandez and Olson breach of duties 

owed to Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional 

distress, loss of personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Benjamin Kutylo seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendants Fernandez and Olson, plus costs 

and a trial by jury on all issues so triable.

COUNT XIV

BENJAMIN KUTYLO - NEGLIGENCE

AGAINST DEFENDANT FARM CLUB AND/OR ITS ASSOCIATION

200. Plaintiff Benjamin Kutylo re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 200 hereof. 

201. At all times material hereto, Defendant Farm Club owed a duty to maintain its 

premises, in a reasonably safe condition, and to take reasonable care for the safety of Plaintiffs and 

protect them from reasonably foreseeable criminal conduct by third parties and employees and 

agents, such as the security guards, to protect the Plaintiffs from being harmed by such persons, 

and further had a duty to implement policies and procedures to protect guests such as Plaintiffs.

202. At all times material hereto, Defendant Farm Club knew or should have known of 

the potential danger in facilitating un-supervised access to renters in a private setting.

203. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendant Farm Club, conducted no criminal background checks about its security company and 

security guard agents and/or any background checks that were performed were patently insufficient.
45

204. Defendant Farm Club knew or should have known there were no keys for the Farm 

House, and that the security cameras were fake.

205. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendant Farm Club as employees, independent contractors 

or agents in allowing the Assailants access to the Farm Club and the Farm House.

206. Defendant Farm Club received direct benefits, including potential or indirect 

benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable care for the 

protection of Plaintiffs to permit only those employees, independent contractors or agents of 

Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; failed to 

warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

207. As a direct and proximate result of Defendant Farm Club’s breach of duties owed to 

Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Benjamin Kutylo seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant Farm Club, plus costs and a trial 

by jury on all issues so triable

COUNT XV

BENJAMIN KUTYLO

VICARIOUS LIABILITY OF

THE FARM CLUB AND/OR ITS ASSOCIATION, AND

FERNANDEZ AND OLSON

208. Plaintiff Benjamin Kutylo re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 208 hereof. 

209. At all times material hereto, Defendants Farm Club, Fernandez and Olson owed a 

duty to maintain their premises, in a reasonably safe condition, and to take reasonable care for the 
46

safety of Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties 

and employees and agents, such as the security guards, to protect the Plaintiffs from being harmed 

by such persons, and further had a duty to implement policies and procedures to protect guests such 

as Plaintiffs.

210. At all times material hereto, Defendants Farm Club, Fernandez and Olson knew or 

should have known of the potential danger in facilitating un-supervised access to renters in a private 

setting.

211. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Farm Club, Fernandez and Olson, conducted no criminal background checks about their

security company and security guard agents and/or any background checks that were performed 

were patently insufficient.

212. Defendants Farm Club, Fernandez and Olson knew or should have known there were 

no keys for the Farm House, and that the security cameras were fake.

213. Defendants Farm Club, Fernandez and Olson are vicariously liable for the conduct 

of the security company and its security guards, as its employees or independent contractor and 

agents, in that they had the right to control and direct the security company and its security guards 

in their duties. 

214. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Farm Club, Fernandez and Olson, as employees, 

independent contractors or agents in allowing the Assailants access to the Farm Club and the Farm 

House. 

215. Defendants Farm Club, Fernandez and Olson received direct benefits, including 

potential or indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable 
47

care for the protection of Plaintiffs to permit only those employees, independent contractors or 

agents of Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; 

failed to warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

216. As a direct and proximate result of Defendants Farm Club, Fernandez and Olson’s

breach of duties owed to Plaintiffs described herein, Benjamin suffered physical pain and suffering, 

emotional distress, loss of personal property, and other damages an amount in excess of $75,000.

WHEREFORE, Plaintiff Benjamin Kutylo seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendants Farm Club, Fernandez and 

Olson, plus costs and a trial by jury on all issues so triable.

COUNT XVI

BENJAMIN KUTYLO

NEGLIGENT HIRING/RETENTION

AGAINST THE FARM CLUB AND/OR ITS ASSOCIATION, AND

FERNANDEZ AND OLSON

217. Plaintiff Benjamin Kutylo re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 217 hereof. 

218. At all times material hereto, Defendants Farm Club, Fernandez and Olson owed a 

duty to maintain its premises, in a reasonably safe condition, and to take reasonable care for the 

safety of Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties 

and employees and agents, such as the security guards, to protect the Plaintiffs from being harmed 

by such persons, and further had a duty to implement policies and procedures to protect guests such 

as Plaintiffs.

219. At all times material hereto, Defendants Farm Club, Fernandez and Olson knew or 

should have known of the potential danger in facilitating un-supervised access to renters in a private 

setting.
48

220. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Farm Club, Fernandez and Olson, conducted no criminal background checks about their

security company and security guard agents and/or any background checks that were performed 

were patently insufficient.

221. Defendants Farm Club, Fernandez and Olson knew or should have known there were 

no keys for the Farm House, and that the security cameras were fake.

222. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Farm Club, Fernandez and Olson as employees, 

independent contractors or agents in allowing the Assailants access to the Farm Club and the Farm 

House. 

223. Defendants Farm Club, Fernandez and Olson received direct benefits, including 

potential or indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable 

care for the protection of Plaintiffs to permit only those employees, independent contractors or 

agents of Defendants Farm Club, Fernandez and Olson who, so far as can be reasonably ascertained, 

pose no threat to such guests; failed to warn Plaintiffs of such danger; and, failed to protect Plaintiffs 

from such danger.

224. By virtue of its business and legal relationships with the Plaintiffs, Defendants Farm 

Club, Fernandez and Olson owed Plaintiffs a duty to not hire and/or retain the dishonest and 

negligent security company and security guards, which Defendants knew or reasonably should have 

known had they engaged in a meaningful and adequate investigation of his background prior to 

hiring them.

225. Plaintiffs were informed and believe, and on that basis allege, that at no time during 

the periods of time alleged did Defendants Farm Club, Fernandez and Olson have in place a system
49

or procedure to reasonably investigate, supervise and/or monitor staff and official resort personnel 

to prevent criminal acts against guests, nor did they implement a system or procedure to oversee or 

monitor conduct toward guests.

226. Defendants Farm Club, Fernandez and Olson were or should have been aware and 

understood how vulnerable guests were to violence through the negligence of security guards and 

other persons of authority within the control of Defendants.

227. Plaintiffs were informed, and believe, and on that basis allege, that the Defendants 

Farm Club, Fernandez and Olson were put on notice that the security company and the security 

guards were unhappy losing their contract and jobs with the Defendants Farm Club, Fernandez and 

Olson because the Defendants Farm Club, Fernandez and Olson had been dissatisfied with the 

ability and performance of the security company and the security guards, and should have foreseen

that the security company and the security guards were engaging in, or would engage in dangerous 

and harmful acts against Plaintiffs under the cloak of their authority, confidence, and trust, 

bestowed upon them through Defendants Farm Club, Fernandez and Olson.

228. Defendants Farm Club, Fernandez and Olson failed to use reasonable care to 

supervise or monitor the security company and the security guards to ensure the safety of guests at 

the Farm House.

229. Defendants Farm Club, Fernandez and Olson’s conduct was a breach of their duty 

to Plaintiffs.

230. As a direct and proximate result of Defendant Farm Club’s breach of duties owed to 

Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages an amount in excess of $75,000.
50

WHEREFORE, Plaintiff Benjamin Kutylo seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendants Farm Club, Fernandez and 

Olson, plus costs and a trial by jury on all issues so triable.

COUNT XVII

BENJAMIN KUTYLO

NEGLIGENCE AGAINST AIRBNB

231. Plaintiff Benjamin Kutylo re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 231 hereof.

232. At all times material hereto, Defendant, AIRBNB, assumed and/or owed a duty to 

take reasonable care for the safety of its customers, including Plaintiffs and to protect them from 

reasonably foreseeable negligent and/or criminal conduct by third parties and employees and 

agents, including the Assailants, the security company and the security guards, and to provide 

sufficient warning of the risk of harm, and to protect the Plaintiffs from being harmed by such 

persons.

233. Defendant, AIRBNB, knew or should have known that there is an industry 

recognized increased danger for United Sates citizens to be susceptible to crime in secluded and 

unfamiliar settings where opportunity is provided for predators to commit crimes against, and/or 

harm to, their persons and property. 

234. At the time of the subject matter, Defendant, AIRBNB, failed to assure or 

negligently attempted to investigate safety of the Defendants Farm Club, Fernandez and Olson,

and/or performed background checks which were patently insufficient.

235. Plaintiffs were vulnerable to the security company and the security guards by virtue 

of their apparent and/or actual authority of the Defendants Farm Club, Fernandez and Olson to 
51

control access to the Farm Club, and to provide Farm House keys and assure that the security 

cameras worked so as to not provide a false sense of security and safety.

236. Defendant, AIRBNB, received some benefit, including potential or indirect benefit, 

by its rental to Allyson, and there exists a duty to exercise reasonable care for the protection of 

guests to permit to enter the Farm Club only those persons who, so far as can be reasonably 

ascertained, would pose no threat to such guests. Defendant, AIRBNB, failed to warn Plaintiffs of 

such danger and failed to protect Plaintiffs from such danger.

237. Defendant, AIRBNB, breached the above referenced duties owed to Plaintiffs, and 

as result thereof, Plaintiffs were falsely imprisoned, assaulted and otherwise traumatized. 

238. As a direct and proximate result of Defendant AIRBNB’s breach of duties owed to 

Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Benjamin Kutylo seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant AIRBNB, plus costs and a trial 

by jury on all issues so triable.

COUNT XVIII

BENJAMIN KUTYLO

VICARIOUS LIABILITY OF AIRBNB

239. Plaintiff Benjamin Kutylo re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 239 hereof.

240. At all times material, Defendant AIRBNB contracted with Defendants Farm Club, 

Fernandez and/or Olson, which in turn subcontracted with the security company and the security 

guards, and/or otherwise vested them with the apparent or actual authority of Defendant, AIRBNB. 

Defendants Farm Club, Fernandez and/or Olson, which in turn subcontracted with the security 
52

company and the security guards, was acting under Defendant AIRBNB’s authority, direct 

supervision, employment and/or control when the wrongful and negligent acts described herein 

were committed. Defendants Farm Club, Fernandez and/or Olson, which in turn subcontracted with 

the security company and the security guards, engaged in this conduct while acting in the course 

and scope of their employment and/or apparent agency and/or actual agency with Defendant 

AIRBNB and/or accomplished the described conduct by virtue of their apparent authority.

241. Defendant, AIRBNB, granted Defendants Farm Club, Fernandez and/or Olson 

authority to perform as an agent within the AIRBNB rented Farm House and otherwise held 

Defendants Farm Club, Fernandez and/or Olson out to the community as a fit and competent agent 

of the resort. Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards committed the acts alleged within the apparent authority arising from the agency. 

Said conduct was undertaken in the course and scope of Defendants Farm Club, Fernandez and/or 

Olson and their security company and security guards’ employment and/or agency regarding rental 

of the Farm House and/or was ratified by Defendant, AIRBNB.

242. Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards were acting at least in part to serve the interests of Defendant, AIRBNB, when 

Defendants Farm Club, Fernandez and/or Olson and their security company and security guards 

committed the negligent acts described herein. Specifically, Defendants Farm Club, Fernandez 

and/or Olson and their security company and security guards were acting as an agent, as well as 

using the trust, power and authority of the position granted, while engaging with Plaintiffs. 

Simultaneously, Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards used that same power and authority to gain Plaintiffs’ confidence and promise them 

Safety and Trust.
53

243. The harm to Plaintiffs caused by Defendants Farm Club, Fernandez and/or Olson 

and their security company and security guards was a foreseeable and well-known hazard of the 

industry as evidenced by AIRBNB’s need to promise Safety and Trust.

244. Because of the Defendants Farm Club, Fernandez and/or Olson and their security 

company and security guards negligent and tortious conduct during their agency relationship with 

Defendant AIRBNB while within the course and scope of their agency and employment, Defendant 

AIRBNB under the law of vicarious liability, including the doctrine of respondeat superior.

245. As a direct and proximate result of Defendant AIRBNB’s breach of duties owed to 

Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Benjamin Kutylo seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant AIRBNB, plus costs and a trial 

by jury on all issues so triable.

COUNT XIX

ALLYSON ESPOSITO - NEGLIGENCE

AGAINST DEFENDANTS FERNANDEZ AND OLSON

246. Plaintiff Allyson Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 246 hereof. 

247. At all times material hereto, Defendants Fernandez and Olson owed a duty to 

maintain its premises, in a reasonably safe condition, and to take reasonable care for the safety of 

Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties and 

employees and agents, such as the security guards, to protect the Plaintiffs from being harmed by 

such persons, and further had a duty to implement policies and procedures to protect guests such as 

Plaintiffs.
54

248. At all times material hereto, Defendants Fernandez and Olson knew or should have 

known of the potential danger in facilitating un-supervised access to renters in a private setting.

249. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Fernandez and Olson, conducted no criminal background checks about their security 

company and security guard agents and/or any background checks that were performed were 

patently insufficient.

250. Defendants Fernandez and Olson knew or should have known there were no keys 

for the Farm House, and that the security cameras were fake.

251. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Fernandez and Olson as employees, independent 

contractors or agents in allowing the Assailants access to the Farm Club and the Farm House.

252. Defendants Fernandez and Olson received direct benefits, including potential or 

indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable care for 

the protection of Plaintiffs to permit only those employees, independent contractors or agents of 

Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; failed to 

warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

253. As a direct and proximate result of Defendants Fernandez and Olson breach of duties 

owed to Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional 

distress, loss of personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Allyson Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendants Fernandez and Olson, plus costs 

and a trial by jury on all issues so triable.
55

COUNT XX

ALLYSON ESPOSITO - NEGLIGENCE

AGAINST DEFENDANT FARM CLUB AND/OR ITS ASSOCIATION

254. Plaintiff Allyson Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 254 hereof. 

255. At all times material hereto, Defendant Farm Club owed a duty to maintain its 

premises, in a reasonably safe condition, and to take reasonable care for the safety of Plaintiffs and 

protect them from reasonably foreseeable criminal conduct by third parties and employees and 

agents, such as the security guards, to protect the Plaintiffs from being harmed by such persons, 

and further had a duty to implement policies and procedures to protect guests such as Plaintiffs.

256. At all times material hereto, Defendant Farm Club knew or should have known of 

the potential danger in facilitating un-supervised access to renters in a private setting.

257. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendant Farm Club, conducted no criminal background checks about its security company and 

security guard agents and/or any background checks that were performed were patently insufficient.

258. Defendant Farm Club knew or should have known there were no keys for the Farm 

House, and that the security cameras were fake.

259. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendant Farm Club as employees, independent contractors 

or agents in allowing the Assailants access to the Farm Club and the Farm House.

260. Defendant Farm Club received direct benefits, including potential or indirect 

benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable care for the 

protection of Plaintiffs to permit only those employees, independent contractors or agents of 
56

Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; failed to 

warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

261. As a direct and proximate result of Defendant Farm Club’s breach of duties owed to 

Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Allyson Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant Farm Club, plus costs and a trial 

by jury on all issues so triable

COUNT XXI

ALLYSON ESPOSITO

VICARIOUS LIABILITY OF

THE FARM CLUB AND/OR ITS ASSOCIATION, AND

FERNANDEZ AND OLSON

262. Plaintiff Allyson Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 262 hereof. 

263. At all times material hereto, Defendants Farm Club, Fernandez and Olson owed a 

duty to maintain their premises, in a reasonably safe condition, and to take reasonable care for the 

safety of Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties 

and employees and agents, such as the security guards, to protect the Plaintiffs from being harmed 

by such persons, and further had a duty to implement policies and procedures to protect guests such 

as Plaintiffs.

264. At all times material hereto, Defendants Farm Club, Fernandez and Olson knew or 

should have known of the potential danger in facilitating un-supervised access to renters in a private 

setting.
57

265. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Farm Club, Fernandez and Olson, conducted no criminal background checks about its 

security company and security guard agents and/or any background checks that were performed 

were patently insufficient.

266. Defendants Farm Club, Fernandez and Olson knew or should have known there were 

no keys for the Farm House, and that the security cameras were fake.

267. Defendants Farm Club, Fernandez and Olson, is vicariously liable for the conduct 

of the security company and its security guards as its employees or independent contractor and 

agents in that it had the right to control and direct the security company and its security guards in 

their duties. 

268. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Farm Club, Fernandez and Olson as employees, 

independent contractors or agents in allowing the Assailants access to the Farm Club and the Farm

House. 

269. Defendants Farm Club, Fernandez and Olson received direct benefits, including 

potential or indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable 

care for the protection of Plaintiffs to permit only those employees, independent contractors or 

agents of Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; 

failed to warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

270. As a direct and proximate result of Defendants Farm Club, Fernandes and Olson’s

breach of duties owed to Plaintiffs described herein, Benjamin suffered physical pain and suffering, 

emotional distress, loss of personal property, and other damages in an amount in excess of $75,000.
58

WHEREFORE, Plaintiff Allyson Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendants Farm Club, Fernandez and 

Olson, plus costs and a trial by jury on all issues so triable.

COUNT XXII

ALLYSON ESPOSITO

NEGLIGENT HIRING/RETENTION

AGAINST THE FARM CLUB AND/OR ITS ASSOCIATION, AND

FERNANDEZ AND OLSON

271. Plaintiff Allyson Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 271 hereof. 

272. At all times material hereto, Defendants Farm Club, Fernandez and Olson owed a 

duty to maintain its premises, in a reasonably safe condition, and to take reasonable care for the 

safety of Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties 

and employees and agents, such as the security guards, to protect the Plaintiffs from being harmed 

by such persons, and further had a duty to implement policies and procedures to protect guests such 

as Plaintiffs.

273. At all times material hereto, Defendants Farm Club, Fernandez and Olson knew or 

should have known of the potential danger in facilitating un-supervised access to renters in a private 

setting.

274. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Farm Club, Fernandez and Olson, conducted no criminal background checks about their

security company and security guard agents and/or any background checks that were performed 

were patently insufficient.

275. Defendants Farm Club, Fernandez and Olson knew or should have known there were 

no keys for the Farm House, and that the security cameras were fake.
59

276. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Farm Club, Fernandez and Olson as employees, 

independent contractors or agents in allowing the Assailants access to the Farm Club and the Farm 

House. 

277. Defendants Farm Club, Fernandez and Olson received direct benefits, including 

potential or indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable 

care for the protection of Plaintiffs to permit only those employees, independent contractors or 

agents of Defendants Farm Club, Fernandez and Olson who, so far as can be reasonably ascertained, 

pose no threat to such guests; failed to warn Plaintiffs of such danger; and, failed to protect Plaintiffs 

from such danger.

278. By virtue of its business and legal relationships with the Plaintiffs Defendants Farm 

Club, Fernandez and Olson owed Plaintiffs a duty to not hire and/or retain the dishonest and 

negligent security company and the security guards.

279. Plaintiffs were informed and believe, and on that basis allege, that at no time during 

the periods of time alleged did Defendants Farm Club, Fernandez and Olson have in place a system

or procedure to reasonably investigate, supervise and/or monitor staff and official resort personnel 

to prevent criminal acts against guests, nor did they implement a system or procedure to oversee or 

monitor conduct toward guests.

280. Defendants Farm Club, Fernandez and Olson were or should have been aware and 

understood how vulnerable guests were to violence through the negligence of security guards and 

other persons of authority within the control of Defendants.

281. Plaintiffs were informed, and believe, and on that basis allege, that the Defendants 

Farm Club, Fernandez and Olson were put on notice that the security company and the security 
60

guards were unhappy losing their contract and jobs with the Defendants Farm Club, Fernandez and 

Olson because the Defendants Farm Club, Fernandez and Olson had been dissatisfied with the 

ability and performance of the security company and the security guards, and should have foreseen

that the security company and the security guards were engaging in, or would engage in dangerous 

and harmful acts against Plaintiffs under the cloak of their authority, confidence, and trust, 

bestowed upon them through Defendants Farm Club, Fernandez and Olson.

282. Defendants Farm Club, Fernandez and Olson failed to use reasonable care to 

supervise or monitor the security company and the security guards to ensure the safety of guests at 

the Farm House.

283. Defendants Farm Club, Fernandez and Olson’s conduct was a breach of their duty 

to Plaintiffs.

284. As a direct and proximate result of Defendant Farm Club, Fernandez and Olson’s

breach of duties owed to Plaintiffs described herein, Benjamin suffered physical pain and suffering, 

emotional distress, loss of personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Allyson Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendants Farm Club, Fernandez and 

Olson, plus costs and a trial by jury on all issues so triable.

COUNT XXIII

ALLYSON ESPOSITO

NEGLIGENCE AGAINST AIRBNB

285. Plaintiff Allyson Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 274 hereof.

286. At all times material hereto, Defendant, AIRBNB, assumed and/or owed a duty to 

take reasonable care for the safety of its customers, including Plaintiffs and to protect them from 
61

reasonably foreseeable negligent and/or criminal conduct by third parties and employees and 

agents, including the Assailants, the security company and the security guards, and to provide 

sufficient warning of the risk of harm, and to protect the Plaintiffs from being harmed by such 

persons.

287. Defendant, AIRBNB, knew or should have known that there is an industry 

recognized increased danger for United Sates citizens to be susceptible to crime in secluded and 

unfamiliar settings where opportunity is provided for predators to commit crimes against, and/or 

harm to, their persons and property. 

288. At the time of the subject matter, Defendant, AIRBNB, failed to assure or 

negligently attempted to investigate safety of the Defendants Farm Club, Fernandez and Olson, the 

security company and the security guards and/or any background checks that were performed were 

patently insufficient.

289. Plaintiffs were vulnerable to the security company and the security guards by virtue 

of their apparent and/or actual authority of the Defendants Farm Club, Fernandez and Olson to 

control access to the Farm Club, and to provide Farm House keys and assure that the security 

cameras worked so as to not provide a false sense of security and safety.

290. Defendant, AIRBNB, received some benefit, including potential or indirect benefit, 

by its rental to Allyson, and there exists a duty to exercise reasonable care for the protection of 

guests to permit to enter the Farm Club only those persons who, so far as can be reasonably 

ascertained, would pose no threat to such guests. Defendant, AIRBNB, failed to warn Plaintiffs of 

such danger and failed to protect Plaintiffs from such danger.

291. Defendant, AIRBNB, breached the above referenced duties owed to Plaintiffs, and 

as result thereof, Plaintiffs were falsely imprisoned, assaulted and otherwise traumatized. 
62

292. As a direct and proximate result of Defendant AIRBNB’s breach of duties owed to 

Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Allyson Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant AIRBNB, plus costs and a trial 

by jury on all issues so triable.

COUNT XXIV

ALLYSON ESPOSITO

VICARIOUS LIABILITY OF AIRBNB

293. Plaintiff Allyson Esposito re-alleges and incorporates paragraphs 1-83 and makes 

them paragraph 282 hereof.

294. At all times material, Defendant AIRBNB contracted with Defendants Farm Club, 

Fernandez and/or Olson, which in turn subcontracted with the security company and the security 

guards, and/or otherwise vested them with the apparent or actual authority of Defendant, AIRBNB. 

Defendants Farm Club, Fernandez and/or Olson, which in turn subcontracted with the security 

company and the security guards, was acting under Defendant AIRBNB’s authority, direct 

supervision, employment and/or control when the wrongful and negligent acts described herein 

were committed. Defendants Farm Club, Fernandez and/or Olson, which in turn subcontracted with 

the security company and the security guards, engaged in this conduct while acting in the course 

and scope of their employment and/or apparent agency and/or actual agency with Defendant 

AIRBNB and/or accomplished the described conduct by virtue of their apparent authority.

295. Defendant, AIRBNB, granted Defendants Farm Club, Fernandez and/or Olson 

authority to perform as an agent within the AIRBNB rented Farm House and otherwise held 

Defendants Farm Club, Fernandez and/or Olson out to the community as a fit and competent agent 
63

of the resort. Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards committed the acts alleged within the apparent authority arising from the agency. 

Said conduct was undertaken in the course and scope of Defendants Farm Club, Fernandez and/or 

Olson and their security company and security guards’ employment and/or agency regarding rental 

of the Farm House and/or was ratified by Defendant, AIRBNB.

296. Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards were acting at least in part to serve the interests of Defendant, AIRBNB, when 

Defendants Farm Club, Fernandez and/or Olson and their security company and security guards 

committed the negligent acts described herein. Specifically, Defendants Farm Club, Fernandez 

and/or Olson and their security company and security guards were acting as an agent, as well as 

using the trust, power and authority of the position granted, while engaging with Plaintiffs. 

Simultaneously, Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards used that same power and authority to gain Plaintiffs’ confidence and promise them 

Safety and Trust.

297. The harm to Plaintiffs caused by Defendants Farm Club, Fernandez and/or Olson 

and their security company and security guards was a foreseeable and well-known hazard of the 

industry as evidenced by AIRBNB’s need to promise Safety and Trust.

298. Because of the Defendants Farm Club, Fernandez and/or Olson and their security 

company and security guards negligent and tortious conduct during their agency relationship with 

Defendant AIRBNB while within the course and scope of their agency and employment, Defendant 

AIRBNB under the law of vicarious liability, including the doctrine of respondeat superior.
64

299. As a direct and proximate result of Defendant AIRBNB’s breach of duties owed to 

Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Allyson Esposito seeks judgment for damages in excess of One

and One Half Million Dollars ($1,500,000) against the Defendant AIRBNB, plus costs and a trial 

by jury on all issues so triable.

COUNT XXV

ALLYSON ESPOSITO AS MOTHER

AND NEXT FRIEND OF TODDLER JANIE DOE - NEGLIGENCE

AGAINST DEFENDANTS FERNANDEZ AND OLSON

300. Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie Doe realleges and incorporates paragraphs 1-83 and makes them paragraph 300 hereof. 

301. At all times material hereto, Defendants Fernandez and Olson owed a duty to 

maintain its premises, in a reasonably safe condition, and to take reasonable care for the safety of 

Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties and 

employees and agents, such as the security guards, to protect the Plaintiffs from being harmed by 

such persons, and further had a duty to implement policies and procedures to protect guests such as 

Plaintiffs.

302. At all times material hereto, Defendants Fernandez and Olson knew or should have 

known of the potential danger in facilitating un-supervised access to renters in a private setting.

303. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Fernandez and Olson, conducted no criminal background checks about their security 

company and security guard agents and/or any background checks that were performed were 

patently insufficient.
65

304. Defendants Fernandez and Olson knew or should have known there were no keys 

for the Farm House, and that the security cameras were fake.

305. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Fernandez and Olson as employees, independent 

contractors or agents in allowing the Assailants access to the Farm Club and the Farm House.

306. Defendants Fernandez and Olson received direct benefits, including potential or 

indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable care for 

the protection of Plaintiffs to permit only those employees, independent contractors or agents of 

Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; failed to 

warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

307. As a direct and proximate result of Defendants Fernandez and Olson breach of duties 

owed to Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional 

distress, loss of personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie 

Doe seeks judgment for damages in excess of One and One Half Million Dollars ($1,500,000) 

against the Defendants Fernandez and Olson, plus costs and a trial by jury on all issues so triable.

COUNT XXVI

ALLYSON ESPOSITO AS MOTHER

AND NEXT FRIEND OF TODDLER JANIE DOE - NEGLIGENCE

AGAINST DEFENDANT FARM CLUB AND/OR ITS ASSOCIATION

308. Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie Doe realleges and incorporates paragraphs 1-83 and makes them paragraph 308 hereof. 

309. At all times material hereto, Defendant Farm Club owed a duty to maintain its 

premises, in a reasonably safe condition, and to take reasonable care for the safety of Plaintiffs and 

protect them from reasonably foreseeable criminal conduct by third parties and employees and 
66

agents, such as the security guards, to protect the Plaintiffs from being harmed by such persons, 

and further had a duty to implement policies and procedures to protect guests such as Plaintiffs.

310. At all times material hereto, Defendant Farm Club knew or should have known of 

the potential danger in facilitating un-supervised access to renters in a private setting.

311. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendant Farm Club, conducted no criminal background checks about their security company and 

security guard agents and/or any background checks that were performed were patently 

insufficient.

312. Defendant Farm Club knew or should have known there were no keys for the Farm 

House, and that the security cameras were fake.

313. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendant Farm Club as employees, independent contractors 

or agents in allowing the Assailants access to the Farm Club and the Farm House.

314. Defendant Farm Club received direct benefits, including potential or indirect 

benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable care for the 

protection of Plaintiffs to permit only those employees, independent contractors or agents of 

Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; failed to 

warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

315. As a direct and proximate result of Defendant Farm Club’s breach of duties owed to 

Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages in an amount in excess of $75,000.
67

WHEREFORE, Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie 

Doe seeks judgment for damages in excess of One and One Half Million Dollars ($1,500,000) 

against the Defendant Farm Club, plus costs and a trial by jury on all issues so triable

COUNT XXVII

ALLYSON ESPOSITO AS MOTHER

AND NEXT FRIEND OF TODDLER JANIE DOE

VICARIOUS LIABILITY OF

THE FARM CLUB AND/OR ITS ASSOCIATION, AND

FERNANDEZ AND OLSON

316. Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie Doe realleges and incorporates paragraphs 1-83 and makes them paragraph 326 hereof. 

317. At all times material hereto, Defendants Farm Club, Fernandez and Olson owed a 

duty to maintain their premises, in a reasonably safe condition, and to take reasonable care for the 

safety of Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties 

and employees and agents, such as the security guards, to protect the Plaintiffs from being harmed 

by such persons, and further had a duty to implement policies and procedures to protect guests such 

as Plaintiffs.

318. At all times material hereto, Defendants Farm Club, Fernandez and Olson knew or 

should have known of the potential danger in facilitating un-supervised access to renters in a private 

setting.

319. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Farm Club, Fernandez and Olson, conducted no criminal background checks about its 

security company and security guard agents and/or any background checks that were performed 

were and/or any background checks that were performed were patently insufficient.

320. Defendants Farm Club, Fernandez and Olson knew or should have known there were 

no keys for the Farm House, and that the security cameras were fake.
68

321. Defendants Farm Club, Fernandez and Olson are vicariously liable for the conduct 

of the security company and its security guards as its employees or independent contractor and 

agents in that they had the right to control and direct the security company and its security guards 

in their duties. 

322. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Farm Club, Fernandez and Olson, as employees, 

independent contractors or agents in allowing the Assailants access to the Farm Club and the Farm 

House. 

323. Defendants Farm Club, Fernandez and Olson received direct benefits, including 

potential or indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable 

care for the protection of Plaintiffs to permit only those employees, independent contractors or 

agents of Defendants who, so far as can be reasonably ascertained, pose no threat to such guests; 

failed to warn Plaintiffs of such danger; and, failed to protect Plaintiffs from such danger.

324. As a direct and proximate result of Defendants Farm Club, Fernandez and Olson’s

breach of duties owed to Plaintiffs described herein, Allyson Esposito as Mother and Next Friend 

of Toddler Janie Doe suffered physical pain and suffering, emotional distress, loss of personal 

property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie 

Doe seeks judgment for damages in excess of One and One Half Million Dollars ($1,500,000) 

against the Defendants Farm Club, Fernandez and Olson, plus costs and a trial by jury on all issues 

so triable.
69

COUNT XXVIII

ALLYSON ESPOSITO AS MOTHER

AND NEXT FRIEND OF TODDLER JANIE DOE

NEGLIGENT HIRING/RETENTION

AGAINST THE FARM CLUB AND/OR ITS ASSOCIATION, AND

FERNANDEZ AND OLSON

325. Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie Doe realleges and incorporates paragraphs 1-83 and makes them paragraph 325 hereof. 

326. At all times material hereto, Defendants Farm Club, Fernandez and Olson owed a 

duty to maintain its premises, in a reasonably safe condition, and to take reasonable care for the 

safety of Plaintiffs and protect them from reasonably foreseeable criminal conduct by third parties 

and employees and agents, such as the security guards, to protect the Plaintiffs from being harmed 

by such persons, and further had a duty to implement policies and procedures to protect guests such 

as Plaintiffs.

327. At all times material hereto, Defendants Farm Club, Fernandez and Olson knew or 

should have known of the potential danger in facilitating un-supervised access to renters in a private 

setting.

328. Prior to and at the time of the subject matter false imprisonment and assaults, 

Defendants Farm Club, Fernandez and Olson, conducted no criminal background checks about its 

security company and security guard agents and/or any background checks that were performed 

were patently insufficient.

329. Defendants Farm Club, Fernandez and Olson knew or should have known there were 

no keys for the Farm House, and that the security cameras were fake.

330. Plaintiffs were defenseless by virtue of their apparent and/or actual authority 

conferred upon the security guards by Defendants Farm Club, Fernandez and Olson as employees, 
70

independent contractors or agents in allowing the Assailants access to the Farm Club and the Farm 

House. 

331. Defendants Farm Club, Fernandez and Olson received direct benefits, including 

potential or indirect benefit, from the AIRBNB rental, and there exists a duty to exercise reasonable 

care for the protection of Plaintiffs to permit only those employees, independent contractors or 

agents of Defendants Farm Club, Fernandez and Olson who, so far as can be reasonably ascertained, 

pose no threat to such guests; failed to warn Plaintiffs of such danger; and, failed to protect Plaintiffs 

from such danger.

332. By virtue of its business and legal relationships with the Plaintiffs Defendants Farm 

Club, Fernandez and Olson owed Plaintiffs a duty to not hire and/or dishonest and negligent security 

company and the security guards.

333. Plaintiffs were informed and believe, and on that basis allege, that at no time during 

the periods of time alleged did Defendants Farm Club, Fernandez and Olson have in place a system

or procedure to reasonably investigate, supervise and/or monitor staff and official resort personnel 

to prevent criminal acts against guests, nor did they implement a system or procedure to oversee or 

monitor conduct toward guests.

334. Defendants Farm Club, Fernandez and Olson were or should have been aware and 

understood how vulnerable guests were to violence through the negligence of security guards and 

other persons of authority within the control of Defendants.

335. Plaintiffs were informed, and believe, and on that basis allege, that the Defendants 

Farm Club, Fernandez and Olson were put on notice that the security company and the security 

guards were unhappy losing their contract and jobs with the Defendants Farm Club, Fernandez and 

Olson because the Defendants Farm Club, Fernandez and Olson had been dissatisfied with the 
71

ability and performance of the security company and the security guards, and should have foreseen

that the security company and the security guards were engaging in, or would engage in dangerous 

and harmful acts against Plaintiffs under the cloak of their authority, confidence, and trust, 

bestowed upon them through Defendants Farm Club, Fernandez and Olson.

336. Defendants Farm Club, Fernandez and Olson failed to use reasonable care to 

supervise or monitor the security company and the security guards to ensure the safety of guests at 

the Farm House.

337. Defendants Farm Club, Fernandez and Olson’s conduct was a breach of their duty 

to Plaintiffs.

338. As a direct and proximate result of Defendant Farm Club, Fernandez and Olson’s

breach of duties owed to Plaintiffs described herein, Benjamin suffered physical pain and suffering, 

emotional distress, loss of personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie 

Doe seeks judgment for damages in excess of One and One Half Million Dollars ($1,500,000) 

against the Defendants Farm Club, Fernandez and Olson, plus costs and a trial by jury on all issues 

so triable.

COUNT XXIX

ALLYSON ESPOSITO AS MOTHER

AND NEXT FRIEND OF TODDLER JANIE DOE

NEGLIGENCE AGAINST AIRBNB

339. Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie Doe realleges and incorporates paragraphs 1-83 and makes them paragraph 339 hereof.

340. At all times material hereto, Defendant, AIRBNB, assumed and/or owed a duty to 

take reasonable care for the safety of its customers, including Plaintiffs and to protect them from 

reasonably foreseeable negligent and/or criminal conduct by third parties and employees and 
72

agents, including the Assailants, the security company and the security guards, and to provide 

sufficient warning of the risk of harm, and to protect the Plaintiffs from being harmed by such 

persons.

341. Defendant, AIRBNB, knew or should have known that there is an industry 

recognized increased danger for United Sates citizens to be susceptible to crime in secluded and 

unfamiliar settings where opportunity is provided for predators to commit crimes against, and/or 

harm to, their persons and property. 

342. At the time of the subject matter, Defendant, AIRBNB, failed to assure or 

negligently attempted to investigate safety of the Defendants Farm Club, Fernandez and Olson, the 

security company and the security guards and/or any background checks that were performed were

patently insufficient.

343. Plaintiffs were vulnerable to the security company and the security guards by virtue 

of their apparent and/or actual authority of the Defendant AIRBNB to control access to the Farm 

Club, and to provide Farm House keys and assure that the security cameras worked so as to not 

provide a false sense of security and safety.

344. Defendant, AIRBNB, received some benefit, including potential or indirect benefit, 

by its rental to Allyson, and there exists a duty to exercise reasonable care for the protection of 

guests to permit to enter the Farm Club only those persons who, so far as can be reasonably 

ascertained, would pose no threat to such guests. Defendant, AIRBNB, failed to warn Plaintiffs of 

such danger and failed to protect Plaintiffs from such danger.

345. Defendant, AIRBNB, breached the above referenced duties owed to Plaintiffs, and 

as result thereof, Plaintiffs were falsely imprisoned, assaulted and otherwise traumatized. 
73

346. As a direct and proximate result of Defendant AIRBNB’s breach of duties owed to 

Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie 

Doe seeks judgment for damages in excess of One and One Half Million Dollars ($1,500,000) 

against the Defendant AIRBNB, plus costs and a trial by jury on all issues so triable.

COUNT XXX

ALLYSON ESPOSITO AS MOTHER

AND NEXT FRIEND OF TODDLER JANIE DOE

VICARIOUS LIABILITY OF AIRBNB

347. Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie Doe realleges and incorporates paragraphs 1-83 and makes them paragraph 347 hereof.

348. At all times material, Defendant AIRBNB contracted with Defendants Farm Club, 

Fernandez and/or Olson, which in turn subcontracted with the security company and the security 

guards, and/or otherwise vested them with the apparent or actual authority of Defendant, AIRBNB. 

Defendants Farm Club, Fernandez and/or Olson, which in turn subcontracted with the security 

company and the security guards, was acting under Defendant AIRBNB’s authority, direct 

supervision, employment and/or control when the wrongful and negligent acts described herein 

were committed. Defendants Farm Club, Fernandez and/or Olson, which in turn subcontracted with 

the security company and the security guards, engaged in this conduct while acting in the course 

and scope of their employment and/or apparent agency and/or actual agency with Defendant 

AIRBNB and/or accomplished the described conduct by virtue of their apparent authority.

349. Defendant, AIRBNB, granted Defendants Farm Club, Fernandez and/or Olson 

authority to perform as an agent within the AIRBNB rented Farm House and otherwise held 

Defendants Farm Club, Fernandez and/or Olson out to the community as a fit and competent agent 
74

of the resort. Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards committed the acts alleged within the apparent authority arising from the agency. 

Said conduct was undertaken in the course and scope of Defendants Farm Club, Fernandez and/or 

Olson and their security company and security guards’ employment and/or agency regarding rental 

of the Farm House and/or was ratified by Defendant, AIRBNB.

350. Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards were acting at least in part to serve the interests of Defendant, AIRBNB, when 

Defendants Farm Club, Fernandez and/or Olson and their security company and security guards 

committed the negligent acts described herein. Specifically, Defendants Farm Club, Fernandez 

and/or Olson and their security company and security guards were acting as an agent, as well as 

using the trust, power and authority of the position granted, while engaging with Plaintiffs. 

Simultaneously, Defendants Farm Club, Fernandez and/or Olson and their security company and 

security guards used that same power and authority to gain Plaintiffs’ confidence and promise them 

Safety and Trust.

351. The harm to Plaintiffs caused by Defendants Farm Club, Fernandez and/or Olson 

and their security company and security guards was a foreseeable and well-known hazard of the 

industry as evidenced by AIRBNB’s need to promise Safety and Trust.

352. Because of the Defendants Farm Club, Fernandez and/or Olson and their security 

company and security guards negligent and tortious conduct during their agency relationship with 

Defendant AIRBNB while within the course and scope of their agency and employment, Defendant 

AIRBNB under the law of vicarious liability, including the doctrine of respondeat superior.
75

353. As a direct and proximate result of Defendant AIRBNB’s breach of duties owed to 

Plaintiffs described herein, Benjamin suffered physical pain and suffering, emotional distress, loss 

of personal property, and other damages in an amount in excess of $75,000.

WHEREFORE, Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie 

Doe seeks judgment for damages in excess of One and One Half Million Dollars ($1,500,000) 

against the Defendant AIRBNB, plus costs and a trial by jury on all issues so triable.

COUNT XXXI

ALL PLAINTIFFS

RICO CIVIL ACTION AGAINST AIRBNB

354. Plaintiff Allyson Esposito as Mother and Next Friend of Toddler Janie Doe realleges and incorporates paragraphs 1-83 and makes them paragraph 354 hereof.

355. At all times material hereto, the actions of Defendant AIRBNB as set forth herein 

constitute unlawful conduct is in violation of 18 U.S.C. §§ 1962(a), (b), (c), and/or (d).

356. AIRBNB is a catalyst for failure to comply with laws, rules and/or regulations.

357. While Defendant AIRBNB requires Hosts to represent and warrant that their listings 

do not breach condominium, lease or rental agreements or homeowners' association pacts and that 

the hosts comply with zoning and other applicable laws and are based upon Trust and Safety, 

Defendant AIRBNB takes no measures to confirm such agreements, pacts, laws, and whether any 

particular rental property is Safe.

358. Defendant, AIRBNB, charges a percentage from Hosts and renters but does not 

investigate and/or monitor property Safety and/or Safety standards.

359. With respect to AIRBNB units and properties not located in a zoning district that 

permits transient occupancy and commercial use of a residential dwelling unit, Defendant, 

AIRBNB, is aiding and abetting wrongful activity.
76

360. Defendant, AIRBNB, is operating a continuing enterprise by effectively converting 

residential units into vacation rentals without complying with any applicable Safety and/or 

regulatory standards.

361. The specific wrongdoers, other than the formal party Defendants listed above, 

include but are not limited to:

a) Brian Chesky, an AIRBNB corporate officer

b) Nathan Blecharczyk, an AIRBNB corporate officer

c) Joseph Gebbia, an AIRBNB corporate officer;

d) Jeffrey Jordan, an AIRBNB corporate officer;

e) Alfred Lin, an AIRBNB corporate officer;

f) Laurence Tosi, an AIRBNB corporate officer; and

g) Defendant Farm Club 

h) Defendant Fernandez

i) Defendant Olson

362. These persons, individually, and in concert with one another, commit the acts set 

forth above as part of an “enterprise” and common plan for the purpose of inducing transactions 

and generating profits, and further:

a) made material misrepresentations about the Trust and Safety with respect to 

renting AIRBNB accommodations including the subject matter AIRBNB Farm House;

b) made material misrepresentations about performing security analyses to 

assess risk to Hosts and guests of the Farm House;

c) charged a percentage from hosts and renters, and collected revenue, but 

failed to pay accommodation taxes in violation of multiple state and federal statutes including , but 

not limited to, F.S. 817.034 and 501.201 and 559.928 and 210.65;

f) made material misrepresentations of safety and alleged utilizing qualified, 

scientific and trustworthy “analytics” to assure patron safety, for the purpose of inducing 
77

transactions for profit in violation of multiple state and federal statutes including, but not limited 

to, F.S. 817.034 and 501.201 and 559.928;

g) AIRBNB’s website claims to be “the easiest way for people to monetize their 

extra space and showcase it to an audience of millions.” However, an increasing amount of 

AIRBNB’s activity, including the activity relating to the subject matter Farm Club and property,

does not originate from the listings of “regular people” who are merely renting out a spare room. 

Instead, professional landlords are providing availability exclusively for tourists, and bypassing 

and/or intentionally violating commercial laws and regulations promulgated for the safety of 

patrons. Contrary to its description of promoting activities of “regular people hosting regular 

people” AIRBNB has mushroomed into a platform that provides for commercial landlords and 

multi-property agents to earn substantial income operating de facto hotels while violating 

commercial laws and regulations promulgated for the safety of patrons;

363. These acts set forth in the preceding allegations are estimated to have been 

committed by the Defendant AIRBNB, and persons enumerated herein, more than thousands of 

times, and are furthermore continuous and have been ongoing from 2010 to present.

364. Plaintiffs’ injuries were the direct result of Defendant AIRBNB’s acts, and the result 

of being induced by Defendant AIRBNB, to travel to the subject matter AIRBNB villa resort, to 

entrust her person and property to the subject matter AIRBNB villa resort, and to pay a fee to 

Defendant AIRBNB, which was the preconceived purpose of Defendant’s commission of the acts 

set forth herein, and the specifically intended consequences of the Defendant AIRBNB’s 

racketeering activities.
78

365. Defendant AIRBNB’s racketeering activities were a substantial and foreseeable 

cause of Plaintiffs’ injuries and the connection between such activities and such result is logical 

and not speculative. 

366. As a direct and proximate result of such racketeering activities, Plaintiffs suffered 

physical pain and suffering, emotional distress, loss of personal property, and other damages an 

amount in excess of $75,000.

WHEREFORE, Plaintiffs and each of them seek judgment for damages against each

Defendant- AIRBNB, Farm Club, Fernandez and/or Olson s in an amount in excess of One and 

One-half Million Dollars ($1,500,000), plus costs and a trial by jury on all issues so triable.

COUNT XXXII

ALL PLAINTIFFS

AGAINST ALL DEFENDANTS, JOINTLY AND SEVERALLY,

FOR VIOLATION OF RIGHT OF PRIVACY 

367. Plaintiffs jointly and separately re-allege and incorporate paragraphs 1-83 and make 

them paragraph 367 hereof.

368. Defendants, and each of them, violated Plaintiffs privacy rights by allowing an 

unwarranted intrusion into their private concerns and interests in unlawfully disclosing and 

disseminating their confidential information to the security company and guards and in turn the 

Assailants and in the guards’ actions in sneaking up on the rental property and peering into the 

sliding door windows without consent.

369. Such intrusions into Plaintiffs’ privacy were substantial and caused physical and 

mental suffering. 

370. As a direct and proximate result of such racketeering activities, Plaintiffs suffered 

physical pain and suffering, emotional distress, loss of personal property, and other damages an 

amount in excess of $75,000.
79

WHEREFORE, Plaintiffs, and each of them, seek judgment for damages against each 

Defendant- AIRBNB, Farm Club, Fernandez and/or Olson in an amount in excess of One and Onehalf Million Dollars ($1,500,000), plus costs and a trial by jury on all issues so triable.

COUNT XXXIII

ALL PLAINTIFFS AGAINST AIRBNB, MATIAS JOSE FERNANDEZ

AND LINDSAY OLSON, JOINTLY AND SEVERALLY, FOR DECEPTIVE

ADVERTISING IN VIOLATION OF FEDERAL LAW

371. Plaintiffs jointly and separately re-allege and incorporate paragraphs 1-370 and 

make them paragraph 371 hereof.

372. Pursuant to the Federal Lanham Act, 15 U.S.C. § 1125, Plaintiffs, and each of them,

bring this action for falsely advertising and misrepresenting the nature, characteristics, qualities of 

goods or services, which misrepresentations Defendants knew to be untrue or misleading intending 

Plaintiffs to rely thereon to Plaintiffs’ detriment.

373. Defendants jointly and severally made false claims that they were trust-worthy and 

concerned about renters’ safety, that they engaged in measures to assure the safety of its renters, 

and here in particular advertised the safety and security of the property and the renters by 

advertising the property as a gated community with security guards who monitor the property and 

which poetry contained fake security cameras and for which Defendants provided no keys.

374. As a direct and proximate result of such racketeering activities, Plaintiffs suffered 

physical pain and suffering, emotional distress, loss of personal property, and other damages an 

amount in excess of $75,000.
80

WHEREFORE, Plaintiffs and each of them seek judgment for damages against each 

Defendant- AIRBNB, Farm Club, Fernandez and/or Olson in an amount in excess of One and Onehalf Million Dollars ($1,500,000), plus costs and a trial by jury on all issues so triable.

Dated this 5th day of May, 2020

Britton Esposito, Christian Fresno, 

Benjamin Kutylo, Allyson Esposito and 

Allyson Esposito as Mother and Next 

Friend of Janie Doe,

Plaintiffs,

By: /s/ Nicholas F. Esposito 

One of Their Attorneys

Nicholas F. Esposito, ARDC 0755176

Bradley K. Staubus, ARDC 6230326

Esposito & Staubus LLP 

7055 Veterans Blvd., Unit B

Burr Ridge, Illinois 60527

(312) 346-2766

nfe@eslaw500.com

bks@eslaw500.com