Jake Retzlaff

Sources

1. Jane Doe AG v. Jake Retzlaff, Utah Xchange, May 22, 2025.
2. Jane Doe AG v. Jake Retzlaff, Utah Xchange, June 27, 2025.
3. Jane Doe AG v. Jake Retzlaff, Utah Xchange, June 30, 2025.
4. Jane Doe AG v. Jake Retzlaff, Utah Xchange, June 30, 2025.

• 1. Jane Doe AG v. Jake Retzlaff

  • 22 May 2025
  • Court record
  • Utah Xchange

  • original
  • archived
  • back to list

  [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.
  4
  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.
  7
  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.
  8
  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.
  9
  GROSS & ROONEY
  /s/ Terence L. Rooney
  Attorneys for Plaintiff

• 2. Jane Doe AG v. Jake Retzlaff

  • 27 Jun 2025
  • Court record
  • Utah Xchange

  • original
  • archived
  • back to list

  Stephen R. Waldron (#6810)
  swaldron@sywlaw.com
  SAVAGE, YEATES & WALDRON, P.C.
  2455 E. Parleys Way, Suite 200 Salt Lake City, Utah 84109 Telephone: (801) 328-2200
  Attorneys for Defendant Jake Retzlaff

  IN THE THIRD JUDICIAL DISTRICT COURT
  IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

  JANE DOE AG, Plaintiff,
  JAKE RETZLAFF; and DOES 1-50, Defendants.

  ANSWER OF JAKE RETZLAFF TO COMPLAINT

  Case No. 250904056 Judge: Hon. Coral Sanchez

  Comes now Jake Retzlaff, the Defendant, who answers Plaintiff A.G.’s (“AG”) Complaint as follows:

  FIRST DEFENSE

  Mr. Retzlaff hereby admits, denies and otherwise responds to the allegations of the Complaint as follows. Mr. Retzlaff denies each and every allegation contained in the Complaint, unless expressly and specifically admitted hereafter.

  1. In response to paragraph 1 of the Complaint, Mr. Retzlaff admits that the plaintiff AG initiated a text exchange with Mr. Retzlaff in which she drove from the University of Utah campus in Salt Lake City to Mr. Retzlaff’s apartment in Provo on the BYU campus, to play video games that evening and sleep over. Mr. Retzlaff specifically and categorically denies each and every and all allegations that he bit, raped or strangled AG, which are ridiculous and bizarre allegations, all of which are false and untrue. Instead, Mr. Retzlaff and AG had a pleasant and entirely consensual evening together, playing video games, and a normal evening of consensual sexual interaction that was uneventful but pleasant, with the plaintiff sleeping over and leaving the next morning to return to Salt Lake City.

  2. In response to paragraph 2 of the Complaint, Mr. Retzlaff lacks sufficient information to form a belief as to whether AG still lives in Salt Lake City in June 2025, but was told by AG that she went to high school in Salt Lake City and attended the University of Utah in November 2023, during their one night together. Plaintiff AG continued to exchange friendly and flirty texts and direct messages with Mr. Retzlaff after their one night together, but none of those texts or DMs revealed directly whether the plaintiff AG continued to reside in Salt Lake or was still attending the University of Utah. Mr. Retzlaff denies allegations related to the current residence of AG due to lack of sufficient information as to her current residence.

  3. In response to paragraph 3 of the Complaint, Mr. Retzlaff is a resident of Provo Utah and a student athlete at Brigham Young University. Mr. Retzlaff is not a resident of Riverside County, California, but did live there when he was in high school, prior to enrolling at Brigham Young University.

  4. In response to paragraph 4 of the Complaint, Mr. Retzlaff does not know who or what is meant or alleged in relationship to Defendants Does 1-50, but specifically denies that there was any abusive or tortious conduct of any kind during their one evening together in November 2023, and further alleges that several of his teammates and a female friend of AG were present for a portion of the evening and the video games, all of whom were able to witness and/or participate in a positive, fun and entirely consensual evening together, and that none of the witnesses present saw or heard anything unpleasant or coercive, and instead, only witnessed polite, courteous, positive and normal consensual behavior and interaction among and between Mr. Retzlaff and AG, who made it clear that she wanted to spend the night with Mr. Retzlaff.

  5. In response to paragraph 5 of the Complaint, Mr. Retzlaff alleges that the proper venue is Provo, Utah, and denies that Salt Lake City, Utah is the proper venue.

  6. In response to paragraph 6 of the Complaint, Mr. Retzlaff lacks sufficient information and belief as to AG’s current residence, and therefore denies the allegation except to admit that jurisdiction would be proper in Provo, Utah.

  7. In response to paragraph 7 of the Complaint, Mr. Retzlaff denies that any amount is in controversy or is owed to AG, and denies the legal conclusion that any particular level or category of discovery is met related to “Tier III” or Rule 26(C)(3).

  8. In response to paragraph 8 of the Complaint, Mr. Retzlaff admits that the Plaintiff AG reached out to him via social media/text to initiate interaction between herself and Mr. Retzlaff on or about October 2023. After their pleasant evening together in November 2023, the Plaintiff AG continued to interact with Mr. Retzlaff with fun and lighthearted text exchanges, concerning the rivalry between Utah football and BYU football. Some examples of these texts from AG after the new year, during January and February 2024, weeks after their one-night sleepover in November 2023, include AG and Mr. Retzlaff having fun ribbing each other over the Utah/BYU football rivalry, as follows:
  Jan. 30, 2024, from AG to Retzlaff: “We (referring to Utah) will win. Trust.”
  Jan. 30, 2024, Retzlaff response to AG: “Sure whatever you say.” Jan. 30, 2024, AG response to Retzlaff: “I’ll bet on it. Ha ha ha.” Jan. 30, 2024, Retzlaff response to AG: “What exactly would you bet.” Jan. 30, 2024, AG response to Retzlaff: “What are you thinking.” Jan. 30, 2024, Retzlaff response to AG: “idk, you tell me.”
  Jan. 30, 2024, AG response to Retzlaff: “no u pick.”
  Jan. 30, 2024, Retzlaff response to AG: “It was ur idea.”
  Jan. 31, 2024, AG response to Retzlaff: “why can’t u just decide.”
  Jan. 31, 2024, AG again follows up due to no response from Retzlaff: “who cares we will win.”
  Jan. 31, 2024, Retzlaff response to AG: “Don’t seem so confident.”
  Feb. 1, 2024, AG response to Retzlaff: “ur coming off of a losing streak.”
  Feb. 1, 2024, Retzlaff response to AG: “Not against Utah.”
  Feb. 1, 2024, AG response to Retzlaff: “wrong we beat you more.” Feb. 1, 2024, Retzlaff response to AG: “We beat you last.”
  Feb. 1, 2024, AG response to Retzlaff: “We? You were still in Cali[fornia].”
  5365790.2
  4

  Feb. 1, 2024, Retzlaff response to AG: “And you act like you were there the last 100 games.”
  Feb. 1, 2024, AG response to Retzlaff: “I was.”
  Feb. 1, 2024, Retzlaff response to AG: “Oh my bad (heart meme).”

  9. Mr. Retzlaff alleges that because their November 2023 consensual sleepover was pleasant and fun and ended well for both parties, that both AG and Mr. Retzlaff were very comfortable texting each other afterwards, and were clearly having fun weeks later in their flirty text exchanges with each other about the BYU/Utah football rivalry. No mention was made by AG during those post-sleepover text exchanges about their evening together being unpleasant, in any way, and at no point does AG claim she was upset or disappointed about their evening together, instead, AG is clearly enjoying their flirty text banter eight weeks later and is urging Mr. Retzlaff to place a fun or flirty bet on the outcome of the upcoming rivalry football game. At the time of the exchange in January/February 2024, BYU’s football record in the season ending 2023 was 5-7 and Mr. Retzlaff was not publicly identified as an NFL draft prospect at the time. Thereafter, and during the next season in 2024, BYU went 11-2 and defeated Colorado in a bowl game in early 2025, with Mr. Retzlaff as the starting quarterback. During BYU’s 2024 11-2 season, plaintiff AG and Mr. Retzlaff had no contact, not even by text, everything was silent. Shortly after BYU’s bowl game win against Colorado, the plaintiff AG hired a Salt Lake City lawyer and made her first ever claim of rape linked to a large monetary demand from Mr. Retzlaff, who by that time was being publicly identified as an NFL draft prospect due to the 11-2 season ending in 2024. Mr. Retzlaff alleges and avers that the reason the plaintiff AG never claimed or even implied any “rape” happened in November 2023, and instead engaged only in fun and flirty text exchanges in the weeks thereafter, is that the plaintiff AG knows perfectly well that no rape occurred and that their evening together was entirely consensual.

  10. In response to paragraphs 9-37 of the Complaint, Mr. Retzlaff does not remember cancelling on prior efforts by AG to drive from the University of Utah in Salt Lake City to be with Mr. Retzlaff, but does admit that AG and her friend drove to Provo to play video games with Mr. Retzlaff at his apartment in Provo, Utah on November 22, 2023, and that AG and her friend did play Fortnite with Mr. Retzlaff, and that during that evening AG and Mr. Retzlaff socialized with and spoke with several of Mr. Retzlaff’s teammates and AG’s friend. Mr. Retzlaff also admits that after AG asked her friend to leave so that he and AG could be together for the evening, that he and AG watched a movie together and started kissing and engaging in fully consensual foreplay, and that the plaintiff AG was excited, interested and very comfortable with the fully consensual sexual interaction between the two of them throughout the entire evening. Mr. Retzlaff specifically and categorically denies that AG was ever scared or in any pain, and further denies that AG said “wait” or “stop” or “no” and instead Mr. Retzlaff alleges that AG was confident and comfortable throughout the entire evening together, and was not instructed to do anything, and instead, was able and willing to initiate consensual sexual interaction that she sought and wanted with and from him, throughout the entire evening. Mr. Retzlaff further denies that he ever raised his voice during the evening, and that AG wanted to perform oral sex on Mr. Retzlaff, which he was comfortable allowing her to do. Mr. Retzlaff admits that he is taller and heavier and stronger than AG, but denies that he in any way used or misused his strength that evening, and further denies any and all allegations that the plaintiff was scared or in any way prevented from leaving at any time she wanted to leave. Mr. Retzlaff further denies any allegation that he bit AG, denies any allegation that he choked AG, denies any allegation that AG had trouble breathing and denies any allegation that AG was pinched by him, and denies any allegation that AG passed out. Mr. Retzlaff denies any allegation that AG was in any pain, denies any allegation that AG cried, and denies any allegation that AG was thrown on her stomach and denies that her head was put in a pillow, and denies any allegation that her hair was pulled and denies any allegation that her necklace was broken. Mr. Retzlaff denies that AG wanted to limit the sexual interaction to just kissing, and instead, alleges that AG wanted to and did engage willfully in normal sexual foreplay, including kissing and touching each other’s genitals, and performing oral sex on Mr. Retzlaff, and having consensual sexual intercourse with the use of a condom for mutual safety and for birth control, and that AG was confident, comfortable and even somewhat bold about what she wanted that evening and how she wanted it to be done. Mr. Retzlaff further alleges that AG’s phone was charging throughout that evening, and at no point did AG indicate in any way that she wanted to leave early, or until the next morning, or that her phone needed a charge, and at no time and in no way did AG ever suggest or indicate in any way that she did not want to be touched or kissed, and instead, just the opposite, AG indicated that she wanted to perform oral sex on Mr. Retzlaff and wanted to have intercourse with Mr. Retzlaff so long as a condom was used for protection and birth control. Mr. Retzlaff denies the allegation that AG “ran” away the next morning; just the opposite, Mr. Retzlaff and AG slept for several hours together in the same bed that evening after their mutual and fully consensual sexual interaction, and without any particular rush, the plaintiff calmly got dressed in a normal fashion while maintaining small talk, and used her phone to text with someone before exchanging a nice hug and a kiss goodbye as she exited Mr. Retzlaff’s apartment, without any complaints about the prior evening and without any suggestion or implication that she was sore or injured or had been mistreated in any way.

  11. In response to paragraphs 38 through 44 of the Complaint, Mr. Retzlaff lacks sufficient information and belief concerning plaintiff AG’s allegations about the plaintiff contacting the Provo police and/or going to a hospital during the week after their one night sleepover, and denies all such allegations on that basis, except to admit to certain facts learned recently from two sources. Mr. Retzlaff and his counsel served a public records act request to attempt to learn who it was that the plaintiff was claiming had raped her, and when. The Provo police department response to the public records request indicates that the plaintiff had a telephonic interview with a trained sexual assault interviewer in Provo, and that she identified her alleged assailant not as Mr. Retzlaff, and instead, identified her assailant as someone she had known from her childhood in Salt Lake City. Because Mr. Retzlaff and AG are not childhood friends, and had only met once, in November 2023, over 18 months ago, and spent one consensual evening together in November 2023 before thanksgiving, it is clear from the Provo police department interview notes that plaintiff AG was identifying someone else as her assailant, other than Mr. Retzlaff, who is not and was not her childhood friend. Mr. Retzlaff alleges and avers on information and belief that the plaintiff AG also had sexual interaction with one or more University of Utah football players at or near that same time, one of whom may be a childhood friend of AG’s from Salt Lake City, but that whichever Utah football players and/or childhood friend of hers that she identified to the police as her assailant is not an NFL draft prospect, and therefore, the plaintiff AG decided more than fifteen months later to change the person accused of rape to instead be Mr. Retzlaff, because by that time, in 2024, Mr. Retzlaff was viewed as an NFL draft prospect after the completion of the 11-2 season, which was 13 months after their consensual one night sleepover. Mr. Retzlaff denies that plaintiff AG has suffered any emotional stress of any kind or amount from their pleasant evening together, denies any and all pain and suffering, and alleges and avers that the plaintiff AG has thus far refused to produce or provide any evidence of a rape kit or a visit to a hospital, and instead, has refused to produce or provide any such evidence. Further, Mr. Retzlaff denies that the plaintiff AG ever identified Mr. Retzlaff as her assailant to the Provo Police, and denies that anyone from the Provo Police department ever told the plaintiff AG that “sexual assault victims never get justice” and that AG’s allegations to that effect is simply a false statement, made in a public pleading.

  12. In response to paragraph 45, Mr. Retzlaff incorporates all of his prior responses in this Answer.

  13. In response to paragraphs 46-50 of the Complaint, Mr. Retzlaff denies each and every allegation therein, and further alleges that the reason the plaintiff AG identified someone else, who she called a “childhood” friend to the Provo Police department as her assailant, and did not identify Mr. Retzlaff as her assailant, is that AG knows full well that their one night get together in November 2023 was pleasant, fun and entirely consensual, but that the plaintiff AG believes that because Mr. Retzlaff is now an NFL draft prospect, that she can extort money from him and that whichever Utah football player was a childhood friend of hers, who she did identify to the police as her assailant, must either be a benchwarmer, or even if a starter for Utah, is not a viable target for payment, and is not an NFL draft prospect.

  14. In response to paragraph 51, Mr. Retzlaff incorporates all of his prior responses in his Answer.

  15. In response to paragraphs 52-57 of the Complaint, Mr. Retzlaff denies each and every allegation therein, and further alleges that the reason the plaintiff AG identified someone else, who she called a “childhood” friend to the Provo Police department as her assailant, and did not identify Mr. Retzlaff as her assailant, is that AG knows full well that their one night get together in November 2023 was pleasant, fun and entirely consensual, but that plaintiff AG believes that because Mr. Retzlaff is now an NFL draft prospect, that she can extort money from him and that whichever Utah football player was a childhood friend of hers, who she did identify to the police department as her assailant, must either be a benchwarmer, or even if a starter for Utah, is not a viable target for payment, and is not an NFL draft prospect.

  16. In response to paragraph 58, Mr. Retzlaff incorporates all of his prior responses in this Answer.

  17. In response to paragraphs 59-62 of the Complaint, Mr. Retzlaff denies each and every allegation therein, and further alleges that the reason the plaintiff AG identified someone else, who she called a “childhood friend” to the Provo Police department as her assailant, and did not identify Mr. Retzlaff as her assailant, is that AG knows full well that their one night get together in November 2023 was pleasant, fun and entirely consensual, but that plaintiff AG believes that because Mr. Retzlaff is now an NFL draft prosect, that she can extort money from him and that whichever Utah football player was a childhood friend of hers, who she did identify to the Provo police as her assailant, must either be a benchwarmer, or even if a starter for Utah, is not a viable target for payment, and it not an NFL draft prospect.

  OTHER DEFENSES

  Mr. Retzlaff asserts the following affirmative defenses to the Complaint, and further reserves the right to supplement the same with additional factual information as discovery progresses in this action and the defense learns more about the meritless allegations directed at Mr. Retzlaff in the Complaint.

  1. The plaintiff AG’s Complaint fails to state a claim against Mr. Retzlaff upon which relief can be granted.

  2. Mr. Retzlaff asserts and alleges that the plaintiff AG did text him to arrange to meet him at his apartment in Provo, and that the Plaintiff AG drove from Salt Lake City to Mr. Retzlaff’s apartment, with a female friend, and that as they played video games together and started to have a good time with one another, that the plaintiff AG, sent her friend away so that she, AG, could be alone with Mr. Retzlaff. Thereafter, the two of them had a fully consensual and pleasant evening together, in which both parties enjoyed it, and neither party was nervous or scared, and after sleeping together in the same bed, the plaintiff texted someone the next morning and after some fun small talk, went home to Salt Lake City.

  3. Thereafter, the plaintiff AG had sex with one or more Utah football players, and four or five days later, told the Provo Police that she was assaulted by a “childhood” friend from Salt Lake City. Mr. Retzlaff and the plaintiff AG are not childhood friends, and met for one night only during college on, November 22, 2023.

  4. The plaintiff AG and Mr. Retzlaff in January and February 2024, eight weeks after their one night of consensual interaction together, continued with flirty and fun text exchanges over the upcoming rivalry football game between BYU and Utah. Thereafter, Mr. Retzlaff did not hear or receive anything from the plaintiff AG until after the completion of an 11-2 football season, when the media started to refer to Mr. Retzlaff as an NFL draft prospect, and with BYU being nationally ranked. After BYU’s 11-2 season, fifteen months after their consensual encounter, AG hired a lawyer and demanded money from Mr. Retzlaff.

  5. The plaintiff AG was either never raped, by anyone, ever, or, because she identified her assailant as a “childhood” friend to the Provo Police, and did not identify Mr. Retzlaff as her assailant, and AG is alleged on information and belief to have had sex with one or more University of Utah football players, her alleged assailant is a University of Utah football player, and not Mr. Retzlaff and not any BYU football player.

  NOTICE OF INTENT TO RELY ON JURY DEMAND

  Mr. Retzlaff hereby gives notice that he relies upon the demand for a jury submitted previously by the Plaintiff, and retains the right to demand a jury if the plaintiff AG later decides to dismiss or waive that right.

  WHEREFORE, having answer the plaintiff’s Complaint, Mr. Retzlaff prays that the Complaint be dismissed, that the Plaintiff AG take nothing, and that Mr. Retzlaff is fully reimbursed for his fees and costs incurred to defend against this meritless case, and that the Court award such other relief as the court deems just and equitable.

  DATED: June 27, 2025
  SAVAGE, YEATES & WALDRON, P.C.
  5365790.2
  By:
  /s/Stephen R. Waldron Stephen R. Waldron
  2455 E. Parleys Way, Suite 200 Salt Lake City, Utah 84109 Attorneys for Defendant

  CERTIFICATE OF SERVICE

  I hereby certify that on the 27th day of June, 2025, I copy of the foregoing ANSWER OF JAKE RETZLAFF TO COMPLAINT was served via the Court’s electronic
  system to the following parties:
  Terence L. Rooney
  J. Adam Sorenson
  GROSS & ROONEY
  215 South State Street, Suite 800 Salt Lake City, UT 84111
  /s/Stephen R. Waldron

• 3. Jane Doe AG v. Jake Retzlaff

  • 30 Jun 2025
  • Court record
  • Utah Xchange

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  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

  Stephen R. Waldron (#6810)
  swaldron@sywlaw.com
  SAVAGE, YEATES & WALDRON, P.C.
  2455 E. Parleys Way, Suite 200 Salt Lake City, Utah 84109 Telephone: (801) 328-2200
  Attorneys for Defendant

  IN THE THIRD JUDICIAL DISTRICT COURT
  IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

  JANE DOE A.G., Plaintiff,
  JAKE RETZLAFF; and DOES 1-50, Defendants.

  JOINT MOTION FOR DISMISSAL
  Case No. 250904056
  Judge: Hon. Coral Sanchez

  The parties, by and through their counsel of record, hereby stipulate, agree, and jointly move the Court to dismiss with prejudice and upon the merits the Plaintiff’s complaint against the Defendant, with each party to bear his or its own attorney’s fees.

  SUBMITTED BY:
  DATED: June 30, 2025
  GROSS & ROONEY
  DATED: June 30, 2025
  SAVAGE, YEATES & WALDRON, P.C.
  By:
  /s/ Terenece L. Rooney Terence L. Rooney
  J. Adam Sorenseon
  215 South State Street, Suite 800 Salt Lake City, Utah 84111 Attorneys for Plaintiff
  By:
  /s/Stephen R. Waldron Stephen R. Waldron
  2455 E. Parleys Way, Suite 200 Salt Lake City, Utah 84109 Attorneys for Defendant

  CERTIFICATE OF SERVICE

  I hereby certify that on the 30th day of June, 2025, a copy of the foregoing JOINT
  MOTION FOR DISMISSAL was served via email to the following party:

  Terence L. Rooney
  J. Adam Sorenson
  GROSS & ROONEY
  215 South State Street, Suite 800 Salt Lake City, UT 84111
  Attorneys for Plaintiff Jane Doe AG
  /s/Stephen R. Waldron

• 4. Jane Doe AG v. Jake Retzlaff

  • 30 Jun 2025
  • Court record
  • Utah Xchange

  • original
  • archived
  • back to list

  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
  Stephen R. Waldron (#6810)
  swaldron@sywlaw.com
  SAVAGE, YEATES & WALDRON, P.C.
  2455 E. Parleys Way, Suite 200 Salt Lake City, Utah 84109 Telephone: (801) 328-2200
  Attorneys for Defendant
  The Order of the Court is stated below:
  Dated:
  June 30, 2025 09:57:21 AM
  /s/ CORAL SANCHEZ District Court Judge
  IN THE THIRD JUDICIAL DISTRICT COURT
  IN AND FOR SALT LAKE COUNTY, STATE OF UTAH
  JANE DOE A.G., Plaintiff,
  JAKE RETZLAFF; and DOES 1-50, Defendants.
  ORDER OF DISMISSAL Case No. 250904056 Judge: Hon. Coral Sanchez

  Based upon the Joint Motion for Dismissal executed by counsel for all parties to this action, and the Court finding good cause for granting the parties’ request for dismissal, it is hereby
  ORDERED that plaintiff’s complaint against the defendant, Jake Retzlaff, is dismissed with prejudice and on the merits, and that each party will bear his or her own costs and attorneys’ fees. _____________________________________________________________________ Executed and entered by the Court as indicted by the date and seal at the top of the first page.

  End of Document

  SUBMITTED BY:
  DATED: June 30, 2025
  GROSS & ROONEY

  By:
  /s/Terence L. Rooney Terence L. Rooney
  J. Adam Sorenseon
  215 South State Street, Suite 800 Salt Lake City, Utah 84111 Attorneys for Plaintiff
  DATED: June 30, 2025
  SAVAGE, YEATES & WALDRON, P.C.
  By:
  /s/Stephen R. Waldron Stephen R. Waldron
  2455 E. Parleys Way, Suite 200 Salt Lake City, Utah 84109 Attorneys for Defendant

  CERTIFICATE OF SERVICE

  I hereby certify that on the 30th day of June, 2025, I served a copy of the foregoing ORDER OF DISMISSAL was served via email to the following party:

  Terence L. Rooney
  J. Adam Sorenson
  GROSS & ROONEY
  215 South State Street, Suite 800 Salt Lake City, UT 84111
  Attorneys for Plaintiff Jane Doe AG
  /s/Stephen R. Waldron

  June 30, 2025 09:57 AM