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Taylor & Ring: Complaint For Personal Injuries and Damages
Taylor & Ring: Complaint For Personal Injuries and Damages
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Attorneys for Plaintiffs,
6 JANE DOE, a minor, by and through her guardian, HEIDI B.,
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HEIDI B., individually, and JACOB B., individually
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF PLACER
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JANE DOE, a minor, by through her guardian, ) CASE NO.
12 HEIDI B.; )
)
HEIDI B., individually; and )
13 COMPLAINT FOR DAMAGES;
JACOB B., individually ) DEMAND FOR JURY TRIAL
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)
Plaintiffs, )
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)
)
-vs.- )
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)
17 PLACER UNION HIGH SCHOOL )
DISTRICT, a public entity; )
)
18 BENJAMIN DUNCAN, individually; and )
DOES 1-60, )
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)
20 Defendants. )
)
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)
)
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)
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Plaintiff, JANE DOE, a minor, by and through her guardian, HEIDI B., HEIDI B., individually,
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and JACOB B., individually hereby file their Complaint and complain and allege as follows:
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THE PARTIES
27 9. The true names and capacities of each defendant designated herein as DOES 1 through
28 60, whether an individual, business, public entity, or some other entity, are presently unknown to
26 with Plaintiff, texting Plaintiff things such as, Be smart. I'm gonna send you an email. Don't reply to it
27 and instructing Plaintiff to erase and clear text messages between them in order to conceal his
28 misconduct.
26 SUPER cheesy and perhaps overly-dramatic. But it was right for that moment and it was an
27 expression of my true feelings that was perfect for the context of the moment. This speech
28 may come [off] as unnecessarily passionate when you look back on it someday (maybe) but
27 19. Given PUHSDs unprecedented decision to protect Duncan and keep him employed at
28 Del Oro High School, Plaintiff and her parents were faced with no option other than to remove Plaintiff
27 32. DUNCAN engaged in other behavior and misconduct that PUHSD knew or should
28 have known about, including improper texting of female students, improper relationships with female
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26 Court.
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26 amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court.
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26 capacity, and other damages, in an amount not yet ascertained, but which exceed the minimum
28 58. Pursuant to Section 52 of the California Civil Code, Plaintiff also seeks exemplary damages
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By:
15 David M. Ring
Sonya Ostovar
16 Attorneys for Plaintiff, JANE DOE,
HEIDI B. and JACOB B.
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Dated: November __, 2017 TAYLOR & RING
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By:
24 David M. Ring
Sonya Ostovar
25 Attorneys for Plaintiff, JANE DOE,
HEIDI B. and JACOB B.
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