Jake Retzlaff

Sources

1. Jane Doe AG v. Jake Retzlaff, Utah Xchange, May 22, 2025.

• 1. Jane Doe AG v. Jake Retzlaff

  • 22 May 2025
  • News article
  • Utah Xchange

  • original
  • archived
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  [Content warning: contains graphic descriptions of sexual assault. Floodlit has redacted certain portions.]

  Terence L. Rooney (#5789)
  trooney@grossrooney.com
  J. Adam Sorenson (#16577)
  asorenson@grossrooney.com
  GROSS & ROONEY
  215 South State Street, Suite 800
  Salt Lake City, Utah 84111
  Telephone: 801-935-4611
  Facsimile: 801-935-4612
  Attorneys for Plaintiff
  IF YOU DO NOT RESPOND TO THIS DOCUMENT WITHIN THE APPLICABLE TIME LIMITS, JUDGMENT COULD BE ENTERED AGAINST YOU AS REQUESTED
  IN THE THIRD JUDICIAL DISTRICT COURT
  SALT LAKE COUNTY, STATE OF UTAH
  JANE DOE A.G.,
  Plaintiff,
  vs.
  JAKE RETZLAFF; and DOES 1–50,
  Defendants.
  AMENDED COMPLAINT
  Case No. 250904056
  Judge Coral Sanchez
  (Tier 3)
  [JURY TRIAL REQUESTED]
  Plaintiff Jane Doe A.G. (“Jane Doe A.G.”) hereby complains, alleges, and avers against Jake Retzlaff (“Retzlaff” or “Defendant”); and Defendant Does 1–50 as follows:1
  Content Warning: the following Complaint contains a detailed account of rape and physical abuse.
  1 The Complaint was Amended to correct a typographical error.
  2
  INTRODUCTION
  1. In November 2023, Jane Doe A.G. and her friend went over to Retzlaff’s apartment to hang out and play video games. Before the night was over, Retzlaff raped, strangled, and bit Jane Doe A.G.
  THE PARTIES
  2. Plaintiff Jane Doe A.G. resides in Salt Lake County, Utah.2
  3. Upon information and belief, Defendant Jake Retzlaff is a resident of Riverside County, California, but currently lives in Utah County, Utah where he is a student at Brigham Young University.
  4. Defendants Does 1–50 are persons or entities not presently known to Plaintiff who enabled Retzlaff’s abuse by concealing his tortious and criminal conduct, negligently or intentionally failing to act on complaints against Retzlaff, or otherwise intentionally or negligently failing to take the steps necessary to protect Plaintiff from Retzlaff. When Plaintiff learns the true identities of Does 1–50, she will amend the Complaint.
  JURISDICTION, VENUE AND TIER
  5. Venue is proper in this Court pursuant to Utah Code § 78B-3a-201(2).
  6. This Court has jurisdiction over the claims asserted herein pursuant to Utah Code Section 78A-5-102.
  7. Because the amount in controversy exceeds $300,000, this case qualifies for Tier III discovery pursuant to Rule 26(c)(3), Utah Rules of Civil Procedure.
  GENERAL ALLEGATIONS
  2 Plaintiff’s full name and identifying information will be filed under seal with the Court and provided to Defendant.
  3
  8. In October 2023, Jane Doe A.G. and Retzlaff connected over social media and began messaging each other.
  9. Over the course of the next few weeks, the two planned a couple times to hang out, but it never worked out since Jane Doe A.G. lived in Salt Lake County and Retzlaff attended BYU.
  10. On or around November 22, 2023, Jane Doe A.G. was hanging out with friends and Retzlaff invited Jane Doe A.G. to come to his place and hang out.
  11. Later that day, Jane Doe A.G. told Retzlaff that she and her friend would stop by that evening if they had time and say hello.
  12. Jane Doe A.G. and her friend went over to his place that evening and went to his room to play Fortnite.
  13. While playing, Jane Doe A.G. spoke to Retzlaff’s friends and teammates.
  14. Later that evening, Jane Doe A.G.’s friend left, and Jane Doe A.G. and Retzlaff started to watch a movie.
  15. At some point they began to kiss, but Jane Doe A.G. did not want to do anything more.
  16. Retzlaff began escalating the situation, attempting to touch her [redacted].
  17. Jane Doe A.G. tried to de-escalate the situation and attempted to slow things down, trying to pull away, and saying “wait.” She did not want to do anything sexual with him.
  18. Retzlaff’s touching then turned more into pinching her hard, and Jane Doe A.G. pushed his hand down. By that point he was causing her pain.
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  19. Despite this, Retzlaff continued to escalate the situation. Jane Doe A.G. wanted to leave, but was scared and felt like she could not get away.
  20. Jane Doe A.G. tried to move away, and said “No,” and “Wait, Stop.” But Retzlaff started to pull her hair, told her to give him oral sex, and pushed her [redacted], causing her to gag and push away.
  21. As the situation continued to escalate, Jane Doe A.G. reacted in a way that made Retzlaff angry. He started to shout at her, and she reached for her phone to call someone, but her phone was dead.
  22. Jane Doe A.G. panicked. Afraid Retzlaff would start yelling again or take her phone from her, she moved to the side of the bed, plugged her phone in, and laid there, waiting for it to charge so she could call her friend.
  23. Soon, Retzlaff was snoring, and Jane Doe A.G. saw that as her chance to get up and leave.
  24. But when she went to get out of the bed, Retzlaff woke up, pushed her back down onto the bed, and started to forcefully kiss her.
  25. Jane Doe A.G. said she needed to get her phone and text her friend, but he got on top of her and started grabbing her [redacted] and kissing her hard.
  26. He was so much stronger, heavier, and taller than Jane Doe A.G. that she felt trapped and scared and was having trouble breathing.
  27. Retzlaff reached beside his bed for a condom and Jane Doe A.G. said Stop! Said No!
  28. When she said this, Retzlaff bit her lip, leaving a cut.
  5
  29. He then put his hands around her neck and started to press down so that she could not breathe.
  30. Jane Doe A.G. felt like she was going to pass out, and she tried to grab his hands and pull her off of him.
  31. Retzlaff pushed her legs up and began to rape her, [redacted], causing pain in her legs, genital area, and abdomen.
  32. It hurt so bad and caused so much pain that Jane Doe A.G. passed out.
  33. At some point she came to as Retzlaff threw her on her stomach and put her head in his pillow.
  34. Jane Doe A.G. remembers tears rolling down her face as she fought to breathe.
  35. Retzlaff put his hands in her hair and pulled against it as her head hit against the wall and she felt pain worse than any she felt before that.
  36. The next thing Jane Doe A.G. remembers is waking up on the bed, and Retzlaff being asleep. Her necklace had broken off her neck when Retzlaff strangled her, and she could not find it.
  37. Jane Doe A.G. grabbed her clothes and her phone and ran.
  38. A few days later, Jane Doe A.G. presented to the hospital where a rape kit was performed and pictures taken of the cut on her lip and the bruises around her neck and on her inner thighs.
  39. Jane Doe A.G. was connected with the Provo Police Department, but initially did not share his name because the officer she spoke to said if she did then detectives would show up at Retzlaff’s house to question him and would share her name with him. She was scared and in shock and not ready to confront him.
  6
  40. At some point after speaking to the police, an officer reached out to her asking for the name because someone else filed a complaint against a football player and the police wanted to see if it was the same person.
  41. At that point, Jane Doe A.G. shared Retzlaff’s name, and the Provo police then encouraged her not to do anything because, as they claimed, “sexual assault victims never get justice.”
  42. A year and a half after the rape and strangulation, Jane Doe A.G. continues to experience extreme post-traumatic stress disorder and other trauma symptoms as she works to process what happened and move on.
  43. Retzlaff committed acts of criminal sexual abuse and battery for no other reason than his own sexual gratification.
  44. Jane Doe A.G. now has to live with the pain and suffering which resulted from those criminal acts.
  FIRST CAUSE OF ACTION
  (Battery)
  45. Plaintiff repeats and realleges each and every allegation above as if set forth in full herein.
  46. In performing the acts described herein, Retzlaff acted with the intent to cause harmful and offensive contacts with Jane Doe A.G.’s person.
  47. On each occasion, Retzlaff did, in fact, bring himself into offensive and unwelcome contact with Jane Doe A.G.
  48. At all relevant times, Jane Doe A.G. found the contacts by Retzlaff to be offensive to her person and dignity, and at no time did Jane Doe A.G. consent to having sex with, being strangled, being bit, or being abused, by Retzlaff.
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  49. As a direct and proximate result of Retzlaff’s unlawful conduct, Jane Doe A.G. suffered emotional distress, humiliation, embarrassment, mental distress, anxiety, and other damages in an amount to be proven at trial, but which are greater than $300,000 each.
  50. Retzlaff committed these wrongful actions with no regard for the harm they caused to Jane Doe A.G. As a result of these willful and deplorable actions, Retzlaff is liable for punitive damages and all attorney fees and costs expended in this action.
  SECOND CAUSE OF ACTION
  (Assault)
  51. Plaintiff repeats and realleges each and every allegation above as if set forth in full herein.
  52. When Retzlaff approached Jane Doe A.G., he intended to cause her apprehension of an imminent harmful and offensive contact with her person.
  53. As a result of Retzlaff’s acts, Jane Doe A.G. was in fact placed in apprehension of imminent harmful and offensive contact with her person.
  54. In performing the acts set forth above, Retzlaff acted with the intent of making contact with Jane Doe A.G.’s person.
  55. At no time did Jane Doe A.G. consent to having sex with, being strangled, being bit, or being abused, by Retzlaff.
  56. As a direct and proximate cause of Retzlaff’s unlawful conduct, Jane Doe A.G. suffered emotional distress, humiliation, embarrassment, mental distress, anxiety, and other damages in an amount to be proven at trial, but which are greater than $300,000 each.
  57. Retzlaff committed these wrongful actions with no regard for the harm they caused to Jane Doe A.G. As a result of these willful and deplorable actions, Retzlaff is liable for punitive damages and all attorney fees and costs expended in this action.
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  THIRD CAUSE OF ACTION
  (Intentional Infliction of Emotional Distress)
  58. Plaintiff repeats and realleges each and every allegation above as if set forth in full herein.
  59. Retzlaff intentionally engaged in acts of sexual battery and assault against Plaintiff, acts considered outrageous and intolerable as they offend generally accepted standards of decency and morality.
  60. Retzlaff intended to cause emotional distress as he sought his own sexual gratification, and any reasonable person would have known that raping, strangling, and biting someone would result in the infliction of emotional distress.
  61. Retzlaff’s conduct proximately caused Plaintiff to suffer severe mental emotional distress which manifested as PTSD, depression, anxiety, horror, grief, shame, embarrassment, humiliation, and other harms.
  62. As a result of these willful and deplorable actions, Retzlaff is liable for punitive damages and all attorney fees and costs expended in this action.
  PRAYER FOR RELIEF
  WHEREFORE, Plaintiff requests the following relief:
  A. On all claims for Relief, judgment in an amount to be proven at trial;
  B. For attorney fees and costs as provided by law;
  C. For punitive damages against Defendant; and
  D. For such other relief as the Court shall deem just and proper.
  JURY DEMAND
  Plaintiff hereby demands a trial by jury on all claims so triable.
  DATED this 22nd day of May, 2025.
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  GROSS & ROONEY
  /s/ Terence L. Rooney
  Attorneys for Plaintiff