The class-action lawsuit filed on behalf of 22 unnamed women against the porn production company Girls Do Porn has been a three-year undertaking, with thousands of pages of filings dating back to the summer of 2016. But buried among the 2,811 documents is a motion labeled “No. 2445.” The filing details a series of sexual-assault allegations levied against Girls Do Porn actor Andre Garcia, a defendant in the case, by over two dozen women, all of whom were once employed by the company and six of whom are plaintiffs in the ongoing trial.

In trial, his deposition, and several discovery hearings, Garcia has refused to answer nearly every question about the case, citing his Fifth Amendment right to avoid self-incrimination. But in court documents, the actor’s attorneys have vigorously denied the accusations on his behalf.

Garcia and several colleagues at the San Diego-based site, including its founder Michael Pratt, stand accused of mounting an elaborate fraud to coerce low-income women ages 18-22 into performing in adult scenes under the guise that the videos would be sold only on DVD to private distributors abroad, and that the models would be able to maintain total anonymity. The 22 plaintiffs and more than a hundred women interviewed for the case have alleged that the opposite was true: that their videos went online immediately, where they were easily identified, doxxed, and harassed.

Last Thursday, the U.S. Attorney in San Diego unsealed an indictment charging Garcia, Pratt, and two other Girls Do Porn employees with several counts of sex trafficking. Garcia was arrested last week; Pratt, who had already fled the country, was named a fugitive. Both maintain their innocence. Monday, a judge denied Girls Do Porn’s filing to “stay,” or halt, the civil trial in the wake of the federal charges. The case resumed that afternoon and will likely conclude later this month.

Motion No. 2445, filed by attorney Brian Holm, who represents the 22 Jane Does, details the rape and assault allegations against Garcia, citing a police report from 2015 and excerpts from victim depositions as evidence. While preparing the case, Holm says he conducted interviews with more than 100 women with similar stories of being defrauded by the company, and nearly two dozen of these women recounted stories of rape, sexual assault or attempted sexual assault by Garcia. The motion argues Garcia had been able to serially assault women “with impunity” because he knew that the models had flown to San Diego in secrecy and would hesitate to call the police. Likewise, because the assaults took place after porn shoots, the motion argues, Garcia had no need to fear the DNA results of a rape kit.

“Plaintiffs’ evidence will show Garcia is a serial sexual assailant,” Holm wrote, “who uses the secrecy of the circumstances to assault young, vulnerable women off-camera for his own personal pleasure. Garcia has used the same tactics, same cheesy lines, and same artifice to lure women to a secluded place where he can force himself on them sexually.”

“ Garcia has used the same tactics, same cheesy lines, and same artifice to lure women to a secluded place where he can force himself on them sexually. ”

The rape allegations have not been mentioned in the first eight weeks of trial, nor will they in the remaining few. When the class-action lawsuit was first filed back in 2016, the plaintiffs included charges of false imprisonment, sexual battery by fraud, and sexual battery by force. According to the filing, Jane Doe Nos. 2, 11, 14, 20, 21, and 22 all reported stories of sexual assault by Garcia. But within a few months, they dropped those charges, the filing states, “to avoid the trauma of plaintiffs having to relive these events.”

In June of this year, Holm filed motion No. 2445 to prohibit Girls Do Porn from discussing the allegations in trial at all. According to Holm, the defense had made a habit of positioning Garcia extremely close to the alleged victims during depositions, where he would interrupt the women as they spoke. The plaintiffs filed a protective motion to end that behavior. But in the June filing, Holm argued that, without interference, Girls Do Porn would continue to use the assaults to conduct a “miniature rape trial,” attempt to undermine the accusers, and thereby derail the broader case. A judge granted the motion.

“During deposition, Defendants tried to impeach Jane Doe No. 2’s overall credibility by pointing out that she went back to Garcia’s apartment the day after the rape to retrieve a jacket she had left there and was again forced to have sex with Garcia and go to dinner with him,” the motion reads. “Defendants argue these actions conflict with Jane Doe No. 2’s claims that Garcia had previously sexually assaulted her after filming. Thus, according to Defendants, Jane Doe No. 2 was lying about the assault in her declaration and cannot be believed for anything she says.”

The stories of assault attributed to Holm in interviews and depositions had several common features. Most recalled Garcia “luring” them back to his apartment. The pretexts for this varied, the motion said. Several claimed Garcia insisted they sleep at his apartment rather than their hotel, because he was responsible for taking them to the airport in the morning and lived closer to the terminals. Others said, while driving them home, he would stage a pitstop at his apartment and invite them up rather than wait in the car. Still more said Garcia hung around the shoots until everyone except the model left before making a move, or attacked them in his car.

In one of the more bizarre instances, an alleged victim (not a plaintiff in the case) told Holm that after filming, she had gone to the bathroom. Once in the restroom, she claimed she received a text from a guy named “Jonathan,” who had been her primary point of contact in arranging the Girls Do Porn job, and whom she believed to be different from the actor. The message claimed they were being kicked out of the hotel and that she should stay at Garcia’s apartment. As the girl would later learn, and as Holm proved during trial, “Jonathan” was Garcia’s alias.

Once alone, Holm alleges in a declaration filed with the motion, Garcia would first attempt consensual sex. His pick-up lines reportedly stuck to a particular script: “that the woman was the most attractive woman he has ever filmed, that the woman should quit what she was doing and move to San Diego to be his ‘girlfriend,’ and that he could take care of her if she moved here because he is rich,” Holm wrote. According to emails read aloud during the deposition, Garcia called one of the models his “sex slave.”

One of the plaintiffs, Jane Doe No. 2, recalled in her declaration that after filming, “Garcia began telling me how pretty I was, that I should be his girlfriend, how he had a really nice car and that he and I should hang out.” She declined, citing an obligation which she was already late for. Garcia then reportedly offered to drive her to her car. But while driving in his Range Rover, Garcia allegedly passed No. 2’s car. Instead, he pulled into a parking lot and turned off the engine. He repeated his pick-up script and made sexual advances. No. 2 tried to leave, but Garcia “began to play with the electronic locks” to keep her in the vehicle.

“ Garcia forcibly removed my clothes. I told him to stop but he did not. Garcia then had intercourse with me in the back seat of the Range Rover without my consent. I told him to stop several times but he would not. ”

According to No. 2’s deposition, this is what followed: “He then climbed over the center console and he tried to mount me. As he was doing so, I slid underneath him into the backseat, hoping to escape the vehicle through the back doors. However, those doors were locked too and I was unable to quickly figure out how to open them. Garcia followed me into the back seat and prevented me from opening the back door. Garcia is a larger male and was easily able to overpower my attempts to get away. Garcia forcibly removed my clothes. I told him to stop but he did not. Garcia then had intercourse with me in the back seat of the Range Rover without my consent. I told him to stop several times but he would not.”

That declaration was recorded in May of 2017. But a police report from November of 2015, which was submitted with the motion, tells an extremely similar story. The report was filed in Newport Beach, California, by another anonymous woman (not a plaintiff in the case). She had encountered Girls Do Porn like most models did: through a Craigslist ad for a company calling itself “Begin Modelling” (the civil trial has detailed that Girls Do Porn used a number of alternative names, allegedly to keep prospective models from encountering their real website).

According to the report, the woman filmed three movies with the company between Sept. 10 and Oct. 1, 2015. The third shoot transpired much like the first two. But when filming ended, the alleged victim found herself alone with Garcia. She got dressed and asked him to call her an Uber. He allegedly refused, saying he “wanted to talk to her.” The woman tried to call a car herself, but found her phone dead. Garcia told her she was “the best girl I’ve been with,” the report reads. He asked her to be his girlfriend. She declined, citing a boyfriend. He asked her to move to San Diego to be his girlfriend. She declined. He offered her $1,000 and promised to take her shopping if she would “just visit him in San Diego some time.” She declined.

Again, the woman asked Garcia to call her a car. Angry, he allegedly grabbed her by the arms, lifted her up, and shrieked that she should be his girlfriend. She repeatedly said “No.” In response, he allegedly picked her up, carried her to the bed, and said: “I’ll show you why you should leave your boyfriend.” At that point, the police report states, the woman began to scream. The report describes the actor removing her clothes, covering her mouth, and raping her, without a condom, for 20 minutes.

Afterwards, the alleged victim asked if she could charge her phone. She got dressed, texted her boyfriend, and called a car. As she waited, the report states, Garcia acted “very nice.” He called her “baby.” He asked why she was mad. Over the next few weeks, the report states, he continued to call her, text her, and ask her to be his girlfriend. She never responded. Once, the woman alleged, he even showed up at her boyfriend’s home in Laguna Beach, pounded on the door, and asked again if she would be his girlfriend. When she threatened to call the police, he left.