CAMDEN, N.J. (CN) – After child-sex charges got guitarist Daniel Jorgensen booted from the Christian synth band Owl City, Jorgensen’s victim casts the other musicians as complicit in a new federal complaint.

Morristown attorney Scott Leonard brought the case Wednesday on behalf of plaintiff K.G., whose real name is being withheld.

“I just think it’s unfortunate that these bands prey on these young girls that are their fans and take advantage of for their own deviant sexual misconduct,” Leonard, who represents K.G.

Filed with a federal judge in Camden, K.G.’s case comes three months after 32-year-old Jorgensen pleaded guilty to fourth-degree lewdness with a minor.

K.G.’s complaint accuses the guitarist of having sexually assaulting her on the beach, but Jorgensen admitted only to exposing himself to a child under the age of 13. He received a sentence of probation from the Atlantic City Superior Court.

Discussing the case in an interview, attorney Leonard called it naive to think that K.G. was the only victim.

“I mean, he was trying to lure [K.G.] onto a tour bus,” Leonard said. “To suggest they had no idea this was going on … I don’t think that’s accurate.”

Leonard said he has spoken with other girls who have alleged abuse by Jorgensen during the same time frame, and that there was a “pattern and practice” of sexual misconduct that the band had to know about.

K.G. was 13 in April 2012 when she first met Jorgensen, having gotten tickets to see Owl City peform at the Verizon Center in Washington, D.C.

The complaint says there was only one reason why the members of Owl City stood around that day outside their tour bus: “for purposes of meeting underage girls.”

K.G. says Jorgensen made sure to get her Facebook details before she left and spent the next year grooming her via webcam sessions for sex.

“He began with increasing frequency to message and video chat with the 13-year-old and he began to ask the plaintiff on a daily basis to send him inappropriate naked pictures of herself and he offered to show her his private parts on his webcam,” the complaint states.

K.G. says the messages on Skype and Facebook increased after Jorgensen invited her to another Owl City concert, this time in Pittsburgh, where he arranged to meet K.G. on the tour bus.

Calling this no isolated incident, the complaint says “other young girls were singled out and targeted by Jorgensen, all right out in the open at the concert venues played by Owl City.”

Owl City’s other members and its representatives at Foundations Artists Management and Creative Artists Agency “knew or … should have known of the egregious pattern of deviant and perverted conduct of defendant Jorgensen,” the complaint states.

K.G. says things became physical with Jorgensen on Aug. 29, 2013, when the guitarist invited her to stay with him alone in his Atlantic City hotel room for a show.

Before the band did their sound check that morning, according to the complaint, Jorgensen lured K.G. to the beach and “defiled” her, according to the complaint.

Apart from the sound check, K.G. says Jorgensen spent the rest of the day with her, “readily visible to … [the] other members of the band and crew.”

K.G. says she and Jorgensen had another sexual encounter on the beach later that day and into the early hours of Aug. 30.

The complaint emphasizes Jorgensen’s attempts to have sex with K.G. on the tour bus.

“Jorgensen displayed no concern or worry that any of the co-defendants would question his bringing a 14-year-old onto the tour bus,” the complaint states.

In addition to Jorgensen, Creative Artists Agency and Foundations Artist Management LLC, the complaint names lead singer Adam Young and band manager Stephen Bursky as defendants.

Owl City was formed in 2007 in Minnesota as a synth pop band that often incorporates Christian faith tropes in its music. In addition to guitar, Jorgensen played vibraphone and bass for the band.

When the band fired Jorgensen in December 2013, the reports of his lewd behavior with fans were still in the rumor stage.

“Please understand that this business decision does not implicate Daniel in the judicial system, but was both necessary and appropriate given the allegations that have surfaced over the last handful of days,” Burksy said in a statement at the time.

Reacting to the lawsuit, Bursky disputed liability.

“We have always condemned, in the strongest possible terms, the actions of Daniel Jorgensen,” Bursky said in an email. “More significantly, we can tell you that none of the other defendants bear any responsibility for Jorgensen’s actions, either factually or legally.”