cory ‘CONFORMED. Yedidsion (SBN 290914) {eae Yeisen SN 37597) ad NIDSION SEBER YEDIDSION LLP AN 14 2015 800 West Sixth Street suite Officer ‘Los Angeles, California 90017 one nee eae ‘Telephone: (310) 277-4277 Facsimile: (310) 277-6277 Attorneys for Plaintiff, AS,, by and through her guardian ad litem, TIFFANY T. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES AS, a minor, by and through her CASE NO: BC 569438 guardian ad litem, TIFFANY T. )COMPLAINT FOR DAMAGES: Plaintiff, 1. NEGLIGENT SUPERVISION OF STUDENTS (Gov't. Code §815.6) 2. NEGLIGENT HIRING, CULVER CITY UNIFIED SCHOOL SUPERVISION, TRAINING, and DISTRICT; JEREMY WEAVER, an RETENTION (Gov't. Code $615.6) individual; STUDENT A, a minor; 3, NEGLIGENCE STUDENT B, a minor; and DOES 1 through 100, Inclusive DEMAND FOR JURY TRIAL Defendants. COME NOW Plaintiff A.S., a minor, by and through her guardian ad litem, TIFFANY T,, to complain of Defendants CULVER CITY UNIFIED SCHOOL DISTRICT; JEREMY WEAVER, an individual; Student A, a minor; Student B, a minor; and DOES 1 through 100, inclusive, based on information and belief, as follows: Due to the nature of the allegations contained herein, the Plaintiff, as a victim of childhood sexual molestation, is identified using only her initials in order to preserve her confidentiality and privacy pursuant to applicable law including Cal. Wel. & Inst. Code § 827; T.N.G. v. Superior Court (1971) 4 Cal3d 767; People v. Ramirez (1997) 55 Cal. App Ath 47 ‘COMPLAINT FOR DAMAGES - 1Cer Ane oN He GENERAL ALLEGATIONS 1. Plaintiff AS. (hereinafter “A.S.” or “Plaintiff”) was at all times relevant to this Complaint a freshman student at Culver City High School (hereinafter “Culver High”) within Defendant CULVER CITY UNIFIED SCHOOL DISTRICT (hereinafter “DISTRICT”) in Culver City, California. 2. Plaintiff is informed and believes that all relevant events in this case occurred within the County of Los Angeles, State of California on or about December 4, 2013 through on or about December 22, 2013 when she was fourteen (14) years of age and a student at Culver High within DISTRICT. 3. Plaintiff was born on April 30, 1999, and at all relevant times was a resident of the county of Los Angeles, California. 4. tall material times mentioned herein, Defendants DISTRICT and DOES 1.50 owned, managed, controlled, maintained, operated, administered, and were otherwise responsible for Culver High and the safety of its students. At Culver High, Defendant DISTRICT provided educational, instructional, recreational, health and related services to AS, and other children. 5. Atall material times mentioned herein, Plaintiff was a minor born on April 30, 1999. 6. Plaintiff was not required to submit a government claim as all of Plaintiff's} claims arise out of C.C.P. $340.1 and those claims involve conduct that occurred after January 1, 2009. Although Plaintiff's claims against the DISTRICT are exempt from the claims presentation requirements of the Gov. Code §905(m), Plaintiff did file said claim on May 30, 2014 against DISTRICT. The claim was thereby rejected on July 24, 2014 by Mike Reynolds, assistant Superintendent of business services at DISTRICT. 7. Plaintiff's claim for negligent supervision of students against DISTRICT is [based upon Government Code §815.6, and the mandatory duties set forth in Education Code §44807 and California Code of Regulations $5531, which provide for the mandatory supervision of students at school and during school-sponsored activities. COMPLAINT FOR DAMAGES - 2eA aAneen a © 8 Plaintiffs claim for negligent hiring, supervision, training and retention against DISTRICT is based on Government Code §815.6 and Education Code §§44660, 44662, 44664, 44830, 44870, 44932, which provide for certain qualifications for the hiring, supervising, evaluating and assessing teachers and for the dismissal of personnel for certain conduct. 9. Plaintiff AS. alleges upon information and belief that between on or about December 4, 2013 through on or about December 22, 2013, A.S. was sexually assaulted by three upper-classmen, Defendant Jeremy Weaver (hereinafter referred to as “Weaver” or “Jeremy Weaver”), Student A, and Student B (collectively referred to as “ ASSAILANTS”) at Culver High within DISTRICT. ASSAILANTS, fellow students at Culver High, were also under DISTRICT's control and supervision. 10, Plaintiff alleges upon information and belief that Defendant Jeremy Weaver was an adult at all relevant times. As a student at Culver High, Defendant Weaver was legally dependent upon the supervision of DISTRICT. As such, DISTRICT ‘was and is responsible for the negligent and/or intentional acts committed by Defendant Weaver. 11. _ Plaintiff alleges upon information and belief that Student A was a minor during all relevant times. Due to Student A’s status as a minor, Student A was legally dependent upon the supervision of DISTRICT. As such, District was and is responsible for the negligent and/or intentional acts committed by Student A. 12. Plaintiff alleges upon information and belief that Student B was a minor during all relevant times. Due to Student B’s status as a minor, Student B was legally dependent upon the supervision of DISTRICT. As such, District was and is responsible for the negligent and/or intentional acts committed by Student B. 13. Plaintiff alleges upon information and belief that DISTRICT had and/or should have had prior notice of ASSAILANTS inappropriate, harassing, and violent conduct and propensities, and therefore were aware of the potential danger and direct threat to DISTRICT students including Plaintiff. Despite this knowledge, Plaintiff COMPLAINT FOR DAMAGES - 3,