Houston: Nigerian socialite sued for rape and battery

8. Defendant Olagundoye, born around August of 1955 or of approximately 60 years of age, is the owner/founder, President, and Director or CEO of Kinghaven Counseling Group, and other business entities mentioned above. He operates his business in the State of Texas. Kinghaven Counseling Group is a facility where patients go to receive counseling for mental or emotional problems, among other things. The facility has hundreds of patients.
—– 9. Plaintiff, a female without work authorization, in her late twenties, met Defendant Olagundoye around August of 2015. At the time, Olagundoye offered Plaintiff a position at Kinghaven. Plaintiff informed him that she had no work permit. By agreement and/or arrangement involving Olagundoye, Plaintiff and Plaintiff’s sister, Plaintiff was to use her sister’s identification card and information to work for Olagundoye at Kinghaven Counseling Group. Thus, Kinghaven registered Plaintiff as its employee under her sister’s ID as Olagundoye informed Plaintiff and her sister that it was a violation of the law to hire someone without work authorization.
—– 10. Consequently, Plaintiff commenced her employment with Kinghaven on or about August of 2015. Though she informed Olagundoye that she had accounting background, Olagundoye informed Plaintiff that he already had an accountant or did not need one, but that he would hire Plaintiff, as a billing clerk. Plaintiff agreed. As a billing clerk, she performed her job diligently, conscientiously and without reproach.
—– 11. Shortly after Plaintiff commenced employment at Kinghaven, however, Defendant Olagundoye, subjected her to horrendous and repetitive incidents of sexual assault and torture as he repeatedly ordered her to report to his office to perform sexual acts on the floor of his office. When Plaintiff rebuffed Olgundoye’s advances and expressed her concerns over the acts, Olagundoye told Plaintiff that there was nothing to worry about as he had a procedure done to his penis that makes him unable to impregnate a woman.
—– 12. In conjunction with that, Olagundoye not only increased Plaintiff’s job duties, he failed to match the increased job duties with a concomitant increase in pay. Significantly, Olagundoye failed to pay Plaintiff, all of her wages and violated Texas labor laws. Specifically, though Plaintiff was hired as a Billing Clerk, she was made to perform the duties of Eligibility Clerk and Authorization Clerk; and yet was not paid in full let alone paid for the increased job duties.
—– 13. Times without number, Olagundoye ordered Plaintiff to report to his office and perform unwanted sexual acts on the floor of his office. Though Plaintiff would cry and beg Olagundoye to stop his reprehensible acts, he failed to heed or budge.
—– 14. On multiple occasions, Olagundoye raped the Plaintiff on the floor of his office. For example, on one of such occasions, Olagundoye twisted Plaintiff’s arms, knocked her onto the floor of his office where the sexual act was usually performed and injured Plaintiff’s arm.
—– 15. On another such occasion, Olagundoye used so much force that Plaintiff got injured and bruised her foot while she was trying to escape and bled. Yet on another such occasion, after Olagundoye had forced Plaintiff to perform sexual acts, he directed her to attend one occasion hosted by or involving Sheila Jackson Lee.
—– 16. A woman appearing to be Olagundoye’s wife attended the ceremony with him but Olagundoye told Plaintiff that she was his sister. On multiple occasions when Plaintiff would scream and state she would no longer report to Olagundoye’s office when so summoned, he threatened her either with reporting her immigration status to the authorities or discharge from employment.
—– 17. Olagundoye perpetuated the perpetration of unlawful, illegal and wrongful sexual acts on the Plaintiff.
—– 18. Around the first week of February 2016, however, when Plaintiff insisted that she was not going to perform sexual act, Olagundoye used undue or inordinate force on Plaintiff, knocked her to the floor of his office multiple times and caused her multiple internal injuries. Essentially, in order to have his way, Olagundoye mercilessly and ruthlessly injured the Plaintiff to the extent that Plaintiff felt that the next time she resisted Olagundoye’s sexual advances, he could kill her.
—– 19. As a result, rather than die at the hands of a rapist, Plaintiff left her employ for her life. Plaintiff’s resignation letter, inter alia reads: “I resigned because of the abuse and sexual slavery you have subjected me to, have become unbearable, and I am left with no other option. I have been reflecting each day, the damage you have been causing me, how traumatizing it has become for me. The way you took advantage of me each time you asked me to see you in your office, the way I had to be forced by you to have sex on the floor of your office – forcing me and twisting my arms to get your way so I can keep a job that I got from you. Sir, I cannot take this anymore and I feel horrible that I could be used in such dehumanizing manner. As I have always told you, if I was your daughter, or relation would you have treated me so horribly? I pray this does not happen to someone else.”
—– 20. Subsequent to Plaintiff’s forced departure from Kinghaven, Olagundoye contacted Plaintiff and told Plaintiff to not do anything stupid or she would regret doing so and that he would get everyone around him to speak against her. From that point on, Plaintiff’s colleagues, friends and superiors at Kinghaven stopped speaking to her. Those who used to call her stopped doing so.
—– 21. Because she was afraid of being deported, Plaintiff did not call the police or go to the authorities to file charges against Olagundoye. She became distraught, dejected and depressed. In conjunction with that, the injuries Olagundoye inflicted on the Plaintiff during the multiple times he raped her, caused Plaintiff to experience and endure severe and virtually unbearable pains.
—– 22. For lack of funds and/or insurance, she could not immediately undergo the necessary medical treatments needed outside of home remedies and over-the-counter medications. For the same reasons, she could not immediately receive professional counseling or therapeutic treatments needed, save from one of her Pastors, who prayed for her and with her over and over again.
—– 23. Essentially, Plaintiff has not only endured physical and psychological trauma but has essentially suffered substantial physical and mental abuse as a result of having been a victim of rape, a criminal activity, perpetrated by the Defendant, Olagundoye.
—– 24. Strangely or ironically, however, Kinghaven Counseling Group, owned and directed by Olagundoye, counsels people who are victims of sexual abuse, people who suffer physical and psychological trauma as well as people who are victims of inter alia, mental and physical abuse. Specifically, Olagundoye’s website inter alia, reads:
Kinghaven Counseling Group is made up of licensed therapists dedicated to helping individuals and families achieve their maximum potential. Each therapist carries a master`s or doctoral degree in counseling or a counseling-related field and has several years of experience. Kinghaven provides a treatment team of specialists to each client served.
Programs and Specialties
Our programs and services provide each client with the appropriate help to reach their maximum potential. Our comprehensive treatment program includes a thorough assessment by a licensed psychologist and therapy by a licensed professional counselor or licensed clinical social worker. …
Our Specialties Our team of trained professionals are experienced in treating a wide variety of issues including:
-Behavior Problems/ School Problems
-Family and Relationship Conflict
-Attention Deficit Disorder/
-Oppositional Defiant Disorder (ODD)
-Depression/Anxiety
-Play Therapy
-Life Transition
-Loss and Grief
-PTSD
-Anger Management/ Stress Management
-Pain/Injury/ Chronic illness
-Substance Abuse / Intervention / Prevention /Dual Diagnosis
-Medication Management
– Abuse/Neglect/Sexual Abuse

—– 25. While Olagundoye operates a business counseling people who have been battered, emotionally and physically traumatized, he repeatedly sexually assaulted the Plaintiff, traumatizing, humiliating and dehumanizing her for approximately six months. Similarly, while operating a business counseling people who are depressed, Olagundoye relentlessly forcefully raped the Plaintiff causing her to be depressed, distressed and devastated.
—– 26. Upon information and belief, this particular occurrence involving Plaintiff, was not the first of its kind for Defendant, Olagundoye. He had previously been charged with sexual harassment on multiple occasions and had quietly resolved those matters.
—– 27. The instant harassment however was sufficiently severe and pervasive and is such as subjected the Plaintiff to not just a hostile work environment but an environment that was shockingly cruel to her being; and was based inter alia, on Plaintiff’s sex. Olagundoye improperly made the performance of forceful, unwanted sexual act, a condition of Plaintiff’s employment to the extent that, by his actions and words, he forced Plaintiff to remain his employee.
—– 28. Both Olagundoye and Plaintiff are originally from Africa and particularly from a culture where someone in the Plaintiff’s position must, of necessity, be fearfully subservient to someone in Olagundoye’s position. A culture where the Master instills fears in the heart of the servant, who can never question the authority or the dictates of the master, regardless of their illegality. Olagundoye’s words and actions in this instance instilled fear in the heart of the Plaintiff to the point that she felt forced to remain on the job or that she could not leave until she felt the next rape incident could result in her death.
—– 29. Specifically, the multiple rape incidents caused Plaintiff’s bones to be deformed as she had inter alia, three disc herniations, lumbar disc disorder, very deep sprain in her left shoulder, numbness in the forearm.
—– 30. Additionally, Olagundoye intentionally, not only knowingly or recklessly caused bodily injury to the Plaintiff; he also intentionally or knowingly threatened the Plaintiff with imminent bodily injury.
—– 31. Plaintiff alleges in the alternative that in Olagundoye’s dealings with and raping the Plaintiff, Olagundoye acted intentionally or recklessly. The emotional distress suffered by the plaintiff was severe. The defendant’s conduct was extreme and outrageous. Olagundoye’s conduct proximately caused the Plaintiff’s emotional distress. No alternative cause of action would provide a remedy for the severe emotional distress caused by the defendant’s conduct.
—– 32. Around March of 2016, when the Plaintiff’s complaint was brought to Olagundoye’s attention, he initially denied the allegations and stated that he and Plaintiff used to date each other and that they had spend nights together in hotels even before she commenced employment at Kinghaven; and that their relationship simply continued after commencement of Plaintiff’s employment at Kinghaven.
—– 33. When Olagundoye saw that his response was debunked, he switched gears and turned around to present a statement purportedly written by one of his friends who falsely stated inter alia, that Plaintiff told him she enjoyed the relationship with Olagundoye; that Plaintiff also told him that Olagundoye is a pleasant man; that the work at Kinghaven was overwhelming and that she decided to break up the relationship she had with Olagundoye.
—– 34. Notably, the particular friend who gave the statement on behalf of Olagundoye had himself been charged with raping another man’s wife. He actually settled the case after his confession but has not satisfied the conditions of settlement.
—– 35. As of the present date, Plaintiff still suffers from the injuries, pain and heartache that emanated from the harrowing experience Olagundoye put her through. Plaintiff did not do anything to contribute to those injuries, pain and heartache. Nor did she do anything to provoke Olagundoye to act the way he did. Plaintiff still needs and seeks treatments for her injuries.
—– 36. In his dealing with the Plaintiff, Olagundoye acted as the founder and/or was the President and Director of Kinghaven Counseling Group. Thus, Kinghaven is equally liable for the conduct of Olagundoye under the doctrine of Respondent Superior.

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