1. John Doe No. 1 Picked Up By John Travolta Personally In A Lexus SUV On January 16th, 2012:
"There were Trojan condoms in the console of the vehicle, and there also appeared to be 2 or 3 wrappers from chocolate cake packages no the floor of the SUV."
2. Arriving At Travolta's Bungalow At The Beverly Hills Hotel:
"The door was unlocked, and there was an overweight black man preparing hamburgers, who meekly said 'hey' (to) Doe Plaintiff No. 1 and (Travolta), and no formal introductions were made. This black man was actually preparing hamburgers, from watching his skill and dexterity in food preparation, it seemed that we was some sort of professional chef."
3. Shamelessly Stripping Naked:
"(Travolta) shamelessly stripped naked in front of Doe Plaintiff No. 1 and the 'chef,' and was gazing at Doe Plaintiff No. 1 as he appeared to be semi-erect."
4. The Massage:
"(Travolta) kept purposely sliding the towel down that covered his buttocks to reveal about half of gluteus area. Doe Plaintiff No. 1 kept sliding the towel back up, and reminding (Travolta) that state law required that a massage client be fully draped during the massage. This back and forth…occurred over ten times in the first hour."
5. Being Left Alone With Travolta:
"(Travolta's) chronograph watch started to chime, and the black chef covered the burgers, and other things he was preparing with plates. The black chef then left the room with a stack of papers, and what appears to be some sort of notebook. No words were exchanged."
6. The First Instance Of Contact:
"(Travolta) started to rub Doe Paintiff No. 1's leg. … Doe Plaintiff No. 1 assumed that it was in fact accidental. Then (Travolta) touched Doe Plantiff No. 1's scrotum, and this time Doe Plaintiff No. 1 told (Travolta) to please not touch him again. (Travolta) apologized, but then snickered to himself like a mischievous child."
7. The Second Instance Of Contact:
"(Travolta) then touched the shaft of Doe Plaintiff No. 1's penis, and seized on to it. (Travolta) quickly tried to rub the head of Doe Plaintiff No. 1's penis as he tried to pull away. This was painful and uncomfortable.
8. An Apology:
"(Travolta) started to apologize for his behavior; and tried to imply that they 'must have gotten our signals crossed', and that he thought that Doe Plaintiff No. 1 'wanted the same thing he did.'"
9. A Proposal:
"(Travolta) then sat up on the table and asked Doe Plaintiff No. 1 to switch places, and do a reverse massage. Doe Plaintiff No. 1 told Defendant that a masseuse lying on the table was unlawful and inappropriate. Then (Travolta) said, 'Come on dude, I'll jerk you off!!!'."
10. Attempting To Leave:
"Doe Plaintiff No. 1 told (Travolta) he just wanted to leave, that the situation was too strange, and that he actually felt very afraid for his safety. (Travolta) then laid down on the table, and said, 'OK, I'll behave myself'. (Travolta) neatly placed the towel in an appropriate manner in his lap and gave Doe Plaintiff No. I confidence that his predatory behavior was finally under control."
11. Say Something Nice To Me:
"Doe Plaintiff No. 1 followed his request with a professional deep tissue massage on his shoulders. (Travolta) then said, 'Say something nice to me.' Doe Plaintiff no. 1 tried to ignore what (Travolta) said, and was hoping to conclude this session. Doe Plaintiff No. 1 looked at (Travolta), who had removed his draping and was masturbating."
12. Sweat Pouring Down His Neck:
"(Travolta's) penis was fully erect, and was roughly 8 inches in length; and his pubic hair was wirey and unkempt. Sweat was pouring down (Travolta's) neck, and he asked Doe Plaintiff No. 1 again to say something nice to him."
13. Lumbering and Bouncing:
"Doe Plaintiff No. 1 moved away from (Travolta), who then lumbered to his feet and began to move towards Doe Plaintiff No. 1 with erect penis bouncing around with his stride. (Travolta) began screaming at Doe Plaintiff No. 1, telling Doe Plaintiff No. 1 how selfish he was.
14. Welcome Back, Kotter And Hollywood's Cabal Of Homosexual Jewish Men:
"(Travolta said he ) got where he is now due to sexual favors he had performed when he was in his 'Welcome Back Kotter' days; and that Hollywood is controlled by homosexual Jewish men who expect favors in return for sexual activity."
15. Things That Will Make You Throw Up:
"(Travolta) then went on to say how he had done things in his past that would make most people throw up. (Travolta explained when he started that he wasn't even gay and that the taste of 'cum' would make him gag. (Travolta also said that he was smart enough to learn to enjoy it, and when he began to make millions of dollars, that it all became well worth it."
16. Sex With Beautiful, Fit Men:
"(Travolta) further explained that the high-class in this world always favor same sex relationships; that sex with beautiful, fit men is actually more intense; and Doe Plaintiff No. 1 would just be open minded enough to let it happen, he would experience the best fucking of his life."
17. A Threat To Call The Police:
"He told (Travolta) to get dressed and to either drive Doe Plaintiff No. 1 back, or Doe Plaintiff No. 1 was going to call the police. Strangely, (Travolta's) penis was still semi-erect, and he had to struggle to get it back into his underwear and jeans since he pulled his underwear and pants up at the same time."
18. A Hollywood Starlet And The Promise Of A Three-Way:
"(Travolta) then said, 'no problem', 'I will find new friends'. (Travolta) then continued to say that Hollywood is all about giving and getting, and then he told Doe Plaintiff No. 1 that he can show me an 'Instant Example'. (Travolta) told Doe Plaintiff No. 1 he knew a Hollywood starlet in the building that wanted three-way sex and to be 'double-penetrated'. (Travolta said they) could have that later, but first the needed to have sex together first before calling her, so this way they would be in-sync with each other sexually."
19. Career Advice:
"(Travolta) told Doe Plaintiff No. 1 that he had Hollywood looks, but just needed to lose some weight and learn to lick some 'ass', and the Doe Plaintiff No. 1 would be ready to make millions and be famous."
20. A Selfish Loser:
"He reiterated his threat to call the police, and (Travolta) took Doe Plaintiff No. 1 back to where he was picked up. During this ride, (Travolta) repeatedly called Doe Plaintiff No. 1 'selfish' and a 'loser', and gave Doe Plaintiff No. 1 double what the was owed. This was $800.00 instead of the $400.00 that (Travolta) was supposed to pay Doe Plaintiff No. 1 for the two hours of massage time spent."
21. John Doe No. 2 Meets "Mr. White" On January 28th, 2012:
"Doe Plaintiff No. 2 … was assigned to do an in-room massage on or about January 28, 2012, a 'Mr. White,' and was told this was an alias for (Travolta). Doe Plaintiff No. 2 does not prefer to do in-room massages and asked coworker to take the assignment, and his coworker declined because (Travolta) had been banned from a Spa that the coworker used to work at in the Los Angeles area."
22. Gluts and Humping:
"He was massaging (Travolta) and at times (Travolta) would hump the table. At one point (Travolta) fell asleep for approximately 5 minutes, and woke up and demanded that his 'gluts' be done immediately…while he was massaging (Travolta's) buttocks area, (Travolta) would open his legs and spread his butt cheeks open, and had an erection…(Travolta) asked him 'can you get right here and pointed and put his hand in his butt.'"
23. Red And Chapped
"(Travolta) said Doe Plaintiff No. 2 had big dense hands…he went to massage (Travolta's) other side, and (Travolta) kept spreading his butt cheeks. Doe Plaintiff No. 2 observed that (Travolta's) butt cheeks and rectum were very red and chapped."
24. Forcing His Hand:
"(Travolta) suddenly turned on his stomach with his legs wide open. He then tried to force Doe Plaintiff No. 2's hand on (Travolta's) scrotum. Then (Travolta) started to grab, rub and caress Doe Plaintiff No. 2's upper thighs and buttocks…(Travolta) also grabbed between Doe Plaintiff No. 2's legs and he pulled away…(Travolta) started masturbating with 15 minutes left in the session, and Doe Plaintiff No. 2 said he had to go."