M.D.                                                    
c/o Sansone Law, LLC                         
7777 Bonhomme Ave, Suite 2250       
Clayton MO 63105                   
                       
    Plaintiff,       

v.               

CORPORATE CASH-FLOW SOLUTIONS,
INC. d/b/a CASH FLOW SOLUTIONS,    
a Missouri corporation,           
                       
AND

JACK T. EIGLES,          

Defendants.           

COME NOW Plaintiff M.D., by and through counsel, and for her cause of action
against Defendants Corporate Cash-Flow Solutions, Inc. d/b/a Cash-Flow Solutions
(hereinafter "Cash-Flow") and Jack T. Eigles (hereinafter "Eigles" or both the Defendants referred to on occasion as "Defendants") states as follows:

1.    Plaintiff M.D. is a resident of Missouri.
2.    Defendant Cash-Flow is a Missouri corporation with its principal place of business in St. Louis County, Missouri.
3.    Defendant Eigles is an individual who resides in St. Louis County, Missouri, and at all times relevant hereto was employed by and served as the president and treasurer of Cash-Flow, was the sole member of its board of directors and was the person who controlled all business activity of Cash-Flow.
4.    From November 2005 through present, M.D. attended several Cash Flow  holiday parties at the invitation of Jack Eigles and at the residence of Jack Eigles that were sponsored by and paid for by Cash Flow.
5.     Between November 2005 through the present without the consent or knowledge of M.D., Eigles, acting within the scope of his employment with Cash-Flow, secretly and privately filmed M.D. on numerous occasions, without her knowledge, while she was in the bathroom at the company holiday party in a state of partial nudity and using the bathroom.
6.    M.D. learned of the videotapes and pictures in February 2010 through police officers investigating the wrongful conduct of Eigles.
7.     The filming equipment was arranged and set up so that it was hidden and not observable by persons using the bathroom.
8.    Following the filming of M.D., and other females, separate defendant
Eigles viewed alone and with others the films or video of M.D. as she was in a state of partial nudity in the bathroom.
9.    On information and belief, Eigles also posted or published the films of M.D., without her consent, on the internet and/or at a locations where others, including the general public, are able to and have view the filmed recordings of M.D. and other women in a state of partial or full nudity, who were also secretly filmed by Eigles, and that the public or other persons viewing the filmed recordings had and have no legitimate concern or reason to view such films or recordings.
10.    As the direct and proximate result of Eigles' secretly filming M.D. and the dissemination of such films, M.D. has suffered and continues to suffer great shame, humiliation, and emotional trauma and distress, including psychological injuries, all of which will continue for the foreseeable future.

For Count I of her Petition against defendants Cash-Flow and Eigles, M.D. states as follows:
11.    M.D. repeats and restates the allegations contained in paragraphs 1 through 10 above and incorporates them herein by reference.
12.    Defendants Cash-Flow and Eigles' filming of M.D. by Eigles, while she was unclothed and using the bathroom with an expectation of privacy, was unreasonable and highly offensive and a wrongful invasion of her privacy.
13.    Defendants Cash-Flow and Eigles' actions were outrageous due to an evil motive and reckless indifference to the rights of M.D. and others who used the bathroom such that M.D. is entitled to an award of punitive damages.

WHEREFORE, on Count I, M.D. prays that this Court enter judgment in her favor and against defendants Corporate Cash-Flow Solutions, Inc. and Jack T. Eigles for compensatory damages in an amount that is fair and reasonable, plus punitive damages in an amount exceeding One Million Dollars ($1,000,000.00), and such other relief as this Court deems just and proper under the circumstances.


For Count II of her Petition against Defendants Cash-Flow and Eigles, M.D. states as follows:
14.    M.D. repeats and restates the allegations contained in paragraphs 1 through 13 above and incorporates them herein by reference.
15.    Defendants Cash-Flow and Eigles published the secretly filmed recordings taken of M.D.
16.     M.D. did not grant Defendants Cash-Flow or Eigles permission to publish the recordings and the public has no legitimate interest in the disclosure of said recordings.
17.    Defendants Cash-Flow and Eigles' disclosure of the films and recordings of M.D. in the bathroom was done in such a way as to bring shame, injury and/or humiliation to M.D.
18.    Defendants Cash-Flow and Eigles' actions were outrageous because of an evil motive or reckless indifference to the rights of M.D. and others who used the bathroom such that M.D. is entitled to an award of punitive damages.

WHEREFORE, M.D. prays that this Court enter judgment in her favor and against Defendants Corporate Cash-Flow Solutions, Inc. and Jack T. Eigles for compensatory damages in an amount that is fair and reasonable, plus punitive damages in an amount exceeding One Million Dollars ($1,000,000.00), and such other relief as this Court deems just and proper under the circumstances.


For Count III of her petition against separate defendant Cash-Flow, M.D. states as follows:
19.    M.D. repeats and restates the allegations contained in paragraphs 1 through 18 above and incorporates them herein by reference.
20.    On information and belief, M.D. states that Eigles and/or Cash-Flow on behalf of Eigles may claim a psychological or psychiatric impairment for Eigles which resulted in his wrongful conduct described in Counts I and II and, if such conditions are claimed in defense or mitigation of Eigles' wrongful conduct, then M.D. further states that Cash-Flow knew or should have known of Eigles' impairments in sufficient time to have taken action to stop Eigles from engaging in such conduct, or to warn unsuspecting women that they were being secretly filmed while fully or partially nude, and that the failure to do so by separate defendant Cash-Flow was careless and negligent, and such carelessness and negligence directly caused or contributed to cause the wrongful and secretive filming of M.D. and others by Eigles as alleged above, and the resulting injuries to M.D. as described herein.
21.    That such conduct and failure to act by Cash-Flow represented a conscious disregard for the safety and health of M.D.

WHEREFORE, on Count III, M.D. prays that this Court enter judgment in her favor and against separate defendant Corporate Cash-Flow Solutions, Inc. for compensatory damages in an amount that is fair and reasonable, plus punitive damages in an amount exceeding One Million Dollars ($1,000,000.00), and such other relief as this Court deems just and proper under the circumstances.