CONWAY, SC (WBTW) – Attorneys for Jane Doe, an alleged rape victim who is suing the Horry County Police Department, claim the county is using “boilerplate” and “generic” excuses to not provide documents and some documents that have been provided appear to be incomplete.

Attorneys for Doe asked a judge to get involved and force the county “to respond fully” in a motion filed Monday in Horry County’s Common Pleas court.WEB EXTRA: Filing by Jane Doe’s attorneys

Doe filed a lawsuit against Horry County in December 2015, claiming she was sexually assaulted for six months by a police detective assigned to her rape case. The detective was not named in the lawsuit, but later filings mention Allen Large. Former Police Chief Saundra Rhodes fired him in July 2015 after allegations of sexual harassment.

The lawsuit also describes “a pattern and practice of allowing and/or condoning inappropriate conduct on behalf of Horry County police officers.”WEB EXTRA: Jane Doe’s lawsuit against Horry County and the Horry County Police Department

Doe’s attorneys asked for a list of documents and information related to the case in February. The county responded in April and, out of 20 requests, her attorneys weren’t satisfied with the response to eight.

The personnel file for Allen Large appeared to be incomplete, Doe’s attorneys said, given how long he worked at the department.

A version of the personnel file provided by the county to News13 is also missing information. Doe’s attorneys mention documents describing a “written reprimand” after a video of Large had “gone viral.” The county left those documents out in the personnel file given to News13. Doe’s attorneys brought up the video because they said the county has refused to give them a copy.

The county also refused to provide a copy of personnel files for two other officers; we have chosen to not name them because News13 hasn’t seen any allegations against them. Doe’s attorneys, however, claim one of the officers was fired the same week as Large for misconduct.

A request for all citizen complaints related to Large appeared to be incomplete, according to the attorneys, but they didn’t say why. The county, again, refused to release complaints tied to another officer who, Doe’s attorneys said, was fired the same week as Large.

Horry County also denied the attorneys’ request for “all citizen complaints pertaining to unwanted sexual advances or sexual assaults by any member of the Horry County Police Department.” The county said the request was too broad, unduly burdensome, and irrelevant. Doe’s attorneys argued the “objections are without merit.”

Attorneys appeared to be searching for other victims with a request for internal affairs files related to a long list of possible allegations, such as an officer abusing his power to pressure rape victims, against any officer in the department.

The county denied it, along with another request for a list of any officers who got in trouble for those allegations. The county called the requests “overly broad, unduly burdensome, and oppressive” – a response given for several requests.

Doe’s attorneys called the objections “generic and boilerplate.” They said the requests would lead to admissible evidence as they try to establish that the police department had a pattern of allowing inappropriate conduct by officers.

The attorneys also reference Large’s testimony in a deposition as evidence that the county knew about problems and didn’t do anything. In that deposition, Large was asked “While employed with the Horry County Police Department, was sexual activity, of any nature, while on duty, permissible?” Large gives several examples.

“But I know we have a lot of incidents of officers doing stuff. We had – you know, one officer had a – had one of the employees in a room, in her office, have sex. Recently a lieutenant was having a relation with the [redacted] secretary. That was a first-class officer. There’s – you know, there’s been officers that have been let go for sending pictures of their private parts to, you know – to people they’ve pulled over and stuff like that.”

…“There’s been a lot of –of things. I mean, there’s a bunch of people still working there who had relationships and did stuff like that. Like I said, [redacted] didn’t – get fired for doing what he did. There’s been a couple of narcotics guys that’ve had sex with their CIs”

Large was asked whether “it was commonplace, in the Horry County Police Department, over the last five years that you were employed there.” He replied, “It’s been there ever since I’ve been there.”

When Doe’s attorneys asked for a “complete set of all policies and procedures, manuals, orders, or directives utilized by the Horry County Police Department from the period of January 2010 to December 2015,” they claim the county only gave them a “table of contents, without copies of any of the policies in place.”

Doe’s attorneys said they’re still waiting for emails and other documents from Horry County Council that are related to the case. “With all due respect, it has been nearly four months since this request was made,” her attorneys wrote, “and had this request been made pursuant to the Freedom of Information Act, the requested documents would have been provided with 14 days.

At the time of publishing this article, News13 hasn’t seen a response from the county to Doe’s attorneys’ motions.

The county’s spokesperson told News13, “It is county policy not to comment on pending litigation.”