Circuit Court for Prince George's Coumty CIVIL - NON-DOMESTIC CASE INFORMATION REPORT. (DIRECTIONS: Plaintif: This Information Report must be completed and attached 1 the complain fled withthe Clerk of Court luiess your case is exempted from the requirement bythe Chief Judge ofthe Court of Appeals pursuant to Rule 211) ‘copy must be included foreach defendant 10 be served. ‘Defendant: You mus fle an Information Report as required by Rule 2-323(h. FoR Eo Ba ARE DEPEND CAS MME — Icast NAME: Jane Doe #3, tal _ vs, PG County Board of Education, el tury DEMAND: Bi} Yes (No Anticipated length of ial hoursor 10 _ days feared Cast PENDINGOBE) ves CDNo ye, Cive ei known: CALTEO2127, CALTETEI36 Brecil Requirements? LJ nerrser Pew ash For CC-DC AT Cas accommodation (Pee atch For CC-DC49) NATURE OF ACTION (CHECK ONE BOX) TORTS TABOR TORTS [otoroe Tort Worker! Comp. Actual Damages (CPPremises Liability Wrongful Discharge IDinder $7,500 Omedicat sits Bassa taney Esrsio-ssowo hrroc Liniiy isso sone0 Chprapeny Damage [dreoessionl Malpractice CONTRACTS ove s1a,000 $ weongt Deas [Diosurace Owaetos Bosiness& Conmerciat Econ udament S set sianse Biter — ICrase Arresvimprisonment TREAT PROPERTY B.CONTRACTS —] © NONMONETARY Bsuisane Iai st [Di toxic Torts [Bcondemnation J under $10,000 declaratory Judgment Brews JV td enn EV sio.000- 20,000 [EXtaivnction visions rosecuton [hover —_|Foverszoo00 Bomer _ reat Pain OTTER astesos ein igs ower Brmionnest Baba hoster ALTERNATIVE DISPUTE RESOLUTION INFORMATION Is his ease appropriate forgferal aan ADR process under Ma, Rule 17-101? (Check gl hat wl) ArMediation BD Yes INo €.Setlement Conference BS Ves B. Arbitration CJ Yes No 1, Neutral Evaluation Yes )No TRACK RVOUR rin ne excpon of ator Couny an Balior i perflte xtimaed LENGTH OF TRLAL ns case WILL TN BE TRACKED ACCORDING! V2 ay of a rl g Vy ott ine 2 aaa me 3 days of tial ie More than 3 days of tril time [PLEASE SEE PAGE TWO OF THIS FORW FOR INSTRUCTIONS PERTAINING TO THE BUSINESS AND. ‘CHNOLOGY CASE MANAGEMENT PROGRAM AND COMPLEX SCIENCE AND/OR MEDICAL CASE MANAGEMENT PROGRAM (ASTAR), AS WELL AS ADDITIONAL INSTRUCTIONS IF YOU ARE FILING YOUR] |COMPLAINT IN BALTIMORE CITY, PRINCE. GEORGE'S COUNTY, OR BALTIMORE COUNTY. Date 1/16 Signature 5 CCDCM O02 Rex. TOI, Page 1 of 3BUSINESS AND TECHNOLOGY CASE MANAGEMENT PROGRAM For all jurisdictions, If Business and Technology track designation under Mf, Rule 16-205 is requested, attach a duplicate ‘copy of complaint and check one of the racks below a Expedited Standard Trial within 7 months Teil within 18 months of Filing of Filing (EMERGENCY RELIEF REQUESTED. ‘COMPLEX SCIENCE AND/OR MEDICAL CASE MANAGEMENT PROGRAM (ASTAR) FOR PURPOSES OF POSSIBLE SPECTAL ASSIGNMENT TO AN ASTAR RESOURCE JODOR wider MA ule 16-2 Please check the applicable box below and atach a duplicate copy of your complains CIE xpeilied Tri! within 7 months of Fling D1 standard - Trial within 18 months oF Fiing /F YOU ARE FILING YOUR COMPLAINT IN BALTIMORE CITY, PRINCE GEORGE'S COUNTY, OR BALTIMORE COUNTY PLEASE FULL OUT THE APPROPRIATE BOX BELOW. CIRCUIT COURT FOR BALTIMORE CITY (CHECK ONLY ONE) OF expeditea ‘Trial 60 to 120 days from notice. Non-jury mater, DF Standard-Short Trial 210 days. DD Standara Trial 360 days. D Lead Paint Fill in: Birth Date of youngest plaintfT DD Asbestos Events and deadlines set by individual judge. GF Protracted Cases Complex cases designated by the Administrative Judge. CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY To asa he Court in determining the appropriate Track Tor this case, chedk one ofthe boxes below. This invonnaion Ws ah fa adenission and may not be used for any pupose other thay Track Assignosent Liability is concedes, 1 Liawity ic not conceded, bu isnt seriously in dspote BB Lisbitity is seriousty in dispute CCDEM O02 (Rev. 2/2010) Page 20f3‘CIRCUIT COURT FOR BALTIMORE COUNTY Expedited ‘Aachment Before Judgment, Declaratory Judgment (Simple), Administrative Appeals, District {Tal Dete-90 days) Court Appeals and Jury Trial Prayers, Guardianship, Injunction, Mandamus. DD standra ‘Condemnation, Confessed Judgments (Vacated), Contract, Employment Related Cases, Fraud and (ial Date-240 deys)Misrepresenttion, Intemational To, Motor Tart, Other Personal Injury, Workers! Compensation Case, 7 Extended Standard Asbestos, Lender Liability, Professional Malpractice, Serious Motor Tort or Personal Injury Cases (rial Date-345 days) (medical expenses and wage loss of $100,000, exper and out-of-state witnesses (paris), nd tral of five or more days), State Insolvency 1D comptex ‘Class Actions, Designated Toxic Tort, Major Construction Contracts, Major Product Liabilities, (Hal Date-480 days) Other Complex Cases CCUDEM 002 (Rev. 2/2010) Page 3 of 3[HE CIRCUIT COURT FOR PRINCE GEORGE’S COUNTY, MARYLAND. JANE DOE #3, INDIVIDUALLY AND AS PARENT AND NEXT FRIEND OF JOHN DOE #3, A MINOR c/o Joseph, Greenwald & Laake, P.A. 6404 Ivy Lane, Suite 400 Greenbelt, MD 20770 Plaintiffs, PRINCE GEORGE'S COUNTY BOARD OF EDUCATION Serve on: Kevin M. Maxwell Chief Executive Officer Case No.: CAL 16- Sasscer Administration Building 14201 Schoo! Lane Upper Marlboro, MD 20772 and PRINCIPAL MICHELLE WILLIAMS 3000 Church Street Glenarden, MD 20706 and GWYNDOLYN MCNAIR 3000 Church Street Glenarden, MD 20706 and DEONTE LAVELL CARRAWAY 7930 Glenarden Parkway, Apt. 514 Lanham, MD 20706Defendants, ‘TAND JURY TRIAL DEMAND COMPLAL COMES NOW, the Plaintiffs, Jane Doe #3, individually and as parent and next friend on behalf of John Doe #3, a minor, by undersigned counsel, Timothy F. Maloney, David M. Simpson, Matthew M. Bryant, Alyse L., Prawde, and Joseph, Greenwald & Laake, P.A., and sues Defendants Prince George’s County Board of Education, Principal Michelle Williams, Fourth Grade Teacher Gwyndolyn McNair, and Deonte Lavell Carraway, and states for cause the following: INTRODUCTION This civil rights lawsuit arises from the sexual abuse and exploitation of numerous elementary schoo! age children at a public school in Prince George’s County, Maryland. This sexual abuse was perpetrated by a teacher's assistant who documented this sexual abuse on his cell phones, This lawsuit is brought on behalf of a nine-year-old victim who specifically told his, fourth-grade teacher of the abuse, and she responded, “I don’t believe you. Go sit down.” The victim is seeking damages against the Board of Education, the school’s principal, the fourth- grade teacher, and the perpetrator whose abuse was made possible by his position at the school and the inaction of the Board and its agents. JURISDICTION AND VE 1. This Court has jurisdiction over the subject matter and all parties pursuant to Md. Code, § 6-102 through § 6-103 of the Courts and Judicial Proceedings Article (“C.J.P, ”). 2. Pursuant to C.J.P. § 6-201, venue in Prince George’s County is proper. All material events occurred in Prince George’s County, Maryland, PARTIES3. Plaintiff Jane Doe #3 is an adult citizen of the State of Maryland who resides in Prince George’s County. Jane Doe #3 sues in her individual capacity and as the mother on behalf of John Doe #3, a minor, John Doe #3 is nine-years-old and is a resident of the State of Maryland. 4, Defendant Prince George’s County Board of Education (the “Board”) constitutes the governing body for the Prince George’s County public school system. The Board's principal office is located at 14201 School Lane in Upper Marlboro, Maryland 20772. The Board is a corporate body created under Md. Code, § 3-103 of the Education Article. At all times mentioned, Deonte Carraway was an agent of Defendant Board as a teacher's assistant at Sylvania Woods Elementary School. 5. Defendant Michelle Williams is an adult citizen of the State of Maryland. At all times relevant to the facts alleged herein, Williams served as the Principal of Judge Sylvania Woods Elementary School, Plaintiffs are suing Principal Williams in her official and individual capacity. 6. Defendant Gwyndolyn MeNair is an adult citizen of the State of Maryland, and she currently serves as a fourth grade teacher at Judge Sylvania Woods Elementary School 7. Defendant Deonte Carraway is an adult citizen of the State of Maryland, He resides at 7930 Glenarden Parkway, Apt. 514, Lanham, MD 20706. At all times relevant to this complaint, he acted in his official capacity as an agent and servant of the Board of Education and in his individual capacity. FACT: IMMON TO ALL. 8. John Doe #3 is nine-years-old and in the fourth grade at Judge Sylvania Woods Elementary School, which is located at 3000 Church Street in Glenarden, Maryland 20706. 9, Atall times relevant to the facts alleged herein, the school was led by Principal Michelle Williams, Principal Williams was a policymaker at Judge Sylvania Woods Elementary Schoolwho had the ability to implement policy, control who is present in the school, control school grounds, and had a duty to monitor and supervise staff members, employces, and others who worked and/or were present on school property for education purposes, including Deonte Carraway, 10, From November 2014 to September 2015, Deonte Carraway was employed as a paid teacher's assistant at Sylvania Woods Elementary School. Since September 2015, Carraway has continued to work at Sylvania Woods Elementary School as a teacher's assistant on an unpaid basis 11. Asa teacher's assistant at the school, Carraway was responsible for the care, supervision, and safety of the students, including John Doe #3. 12, Carraway used his position as a teacher’s assistant to sexually assault and prey on students at Sylvania Woods Elementary School. Specifically, his status as a teacher's assistant permitted him access to the school, the auditorium, and the bathrooms with elementary age lren. Carraway’s status as a teacher’s assistant also permitted him to remove students from class and escort them to various locations within the school building, which made possible this sexual abuse and exploitation. 13, While in the schoo! building during school hours, Carraway pressured and/or coerced students to engage in sexual acts with him. Carraway recorded this criminal sexual abuse of the minor children on his cell phone, 14, Carraway also pressured, coerced, and enticed children who were students at Sylvania Woods Elementary to perform sexual acts with each other that he filmed on his phone, Carraway used his status as an adult, a school employee, and agent of the school to persuade school children at Sylvania Woods, including the plaintiff John Doe #3, to perform sexual actsthat he filmed, Carraway told some of the students that they would be participating in a “club” with him to help persuade them to engage in these sexual acts on camera. The children that he persuaded to film these acts were as young as nine years old, Upon information and belief, the number of victims is at least 17, but it may be as many as 30. 15. The filming of these sexual acts took place openly in the school building during school hours, including in such open places as the school auditorium, as well as in the bathrooms and other locations on school property, Carraway was able to openly entice these children to perform sexual acts openly on school property because of the complete absence of any supervision and oversight of his conduct or behavior involving these children. 16, Plaintiff John Doe #3 is nine-years-old and was vulnerable to the influence of an adult authority figure such as Carraway. During schoo! hours on school property, Carraway enticed Plaintiff #3 to perform sexual acts on camera. Carraway filmed these sexual acts for his own gratification and with the intent to use the images of this child sexual activity for exploitive purposes. Carraway would call the children out of their classrooms and escort them to different locations on school property for the purposes of sexually abusing the students and/or recording the abuse on his cellular phone. Carraway was able to exercise this control over students by virtue of his position of trust and authority at the school, which was conferred upon him by Defendants Board of Education and Principal Williams. 17. John Doe #3 is currently a fourth grade student at Sylvania Woods and is one of Carraway’s victims. 18. Carraway pulled John Doe #3 out of class by telling him that Principal Williams wanted to speak with him. Carraway took John Doe #3 to the dressing room behind the stage in the auditorium, John Doe #3 went with Carraway because he thought that was where PrincipalWilliams wanted to talk with him. When they got there, another male student in John Doe #3°s class was already in the dressing room with his pants pulled down, Carraway directed John Doe #3 to pull down his pants, John Doe #3 said “no” over and over again, He repeatedly told Carraway that he wanted to leave 19, To keep John Doe #3 from leaving, Carraway took out a phone and told John Doe #3 that he was calling the police. Fearful of the threat, John Doe #3 complied with Carraway’s demands. Carraway then directed the other student to perform a sex act with John Doe #3. Carraway propped up a different cell phone in the room and began recording, He left the room but continued to direct them from outside the door and threatened them if they stopped. Specifically, Carraway told John Doe #3 that, “[iJf you pull your pants back up, I am going to tell everyone you were raping [name omitted].” Shortly after, John Doe #3 pushed open the door and ran out of the dressing room and back to class 20, When John Doe #3 arrived at his math class, he immediately walked up to his teacher, Gwyndolyn McNair, and reported Carraway’s criminal actions, John Doe #3 told McNair that “Deonte wanted [name omitted] to hump me.” 21. In response, MeNair told him, “I don’t believe you. Go sit down.” 22. The other student was not in the class at this time. McNair made no attempts to locate the other student. 23, MeNair never spoke again with John Doe #3 about what happened or asked him any questions. 24. McNair never informed his mother, Jane Doe #3, of what he had reported to her. 25. Despite John Doe #3’s statement to MeNair that “Deonte wanted [name omitted] to hump: me,” Carraway was permitted to continue working at the school, pulling students out of class,and escorting them to various locations within the schoo! building for the purpose of sexually abusing them and recording the abuse with his cell phones. 26, On a separate occasion, while John Doe #3 was on the school playground, Carraway showed him a pornographic video of two Sylvania Woods students. 27. In January 2016, the uncle of another Sylvania Woods’ student discovered that Carraway had been communicating with that student and other children on Kik, a mobile messaging application which allows individuals to anonymously send messages, photographs, and videos The student's uncle, who periodically checks the student's phone, saw on his cell phone that there were inappropriate pictures of students that were sent through 28, That student’s uncle and guardian notified the administration at Sylvania Woods Elementary School about the inappropriate pictures and messages from Carraway. On February 4, 2016, they met with Assistant Principal Donna Smith and Principal Michelle Williams and showed them the photographs on the student’s phone. Principal Williams told the student’s uncle and Jane Doe to return to the schoo! the next day for another meeting, 29. That night, the student’s uncle contacted the Prince George’s County Police Department about the pictures and messages. 30. Upon initiating an investigation, Prince George’s County Police Department discovered four SIM cards from Carraway’s mobile phone. On just one of the SIM cards, there were at least 44 recordings of sexual acts involving children. 31. Upon information and belief, in some of the recordings, Carraway can be seen or heard directing the children to perform certain sexual acts. 32. Upon information and belief, one of the recordings is of a child performing a sexual act in a school bathroom while he recorded the act on his cell phone, on Carrawé33. Upon information and belief, the obscene recordings on Carraway’s phone range from cight-second clips to videos running over a minute. 34, Upon information and belief, the recordings have been made since at least carly 2015 and continued until Carraway’s arrest on February 5, 2016. 35, Atall times relevant to this complaint, Carraway acted as an agent of the Board and this, status and position of influence, control, and authority conferred by the Board permitted, facilitated, enabled, and caused this conduct to occur. Specifically, during the school day and on school property, the Board gave Carraway access to elementary age students, including John Doe #3. The Board gave Carraway a position of influence over these students, including John Doe #3. ‘The Board gave Carraway control of these students and permitted Carraway to have and use his authority as a teacher's assistant to remove students from classrooms, transport the students to bathrooms, auditoriums, or other locations on school property, and perpetrate this sexual abuse during the school day, which he documented by recording these acts. 36, Carraway’s abuse was common knowledge among the students at Sylvania Woods Elementary School 37. At least one teacher, Gwendolyn McNair, had actual knowledge based on John Doe #3°s report that Carraway was abusing children at the school. 38. Parents and teachers at Sylvania Woods Elementary School had expressed concern and/or raised issues about Carraway’s predatory behavior to Principal Michelle Williams, but she took no action. 39, Principal Williams refused to take any action because she claimed the teachers had “no proof” of Carraway’s actions,40, Such statements were clearly untrue, given what John Doe #3 had told his teacher, Gwendolyn McNair, concerning what Carraway coerced him to do on school property 41. Upon information and belief, the administration knew or should have known about Carraway’s predatory conduct, but Principal Williams and the Board failed to remove him from the school in a timely manner. 42. Upon information and belief, agents of the Board «d to promptly report these concerns in violation of Maryland law with respect to promptly reporting sexual abuse as required by Md. Code, § 5-704 of the Family Law Article. F.L. § 5-704 requires educators, among others, to notify the appropriate authorities soon as possible” and submit a “written report” within 48 hours if the educator has “reason to believe that a child has been subjected to abuse or neglect.” 43. On or about February 5, 2016, as a result of this criminal sexual child abuse, Carraway was arrested and charged with ten counts of felony child pornography in violation of Md. Code, § 11-207 of the Criminal Law Article, one count of sexual abuse of a minor in violation of Md, Code, § 3-602 of the Criminal Law Article, and one count of second-degree sex offense in violation of Md. Code, § 3-306 of the Criminal Law Article, See State v. Deonte Lavell Carraway, Case No.: 5E00605015 (District Court of Maryland for Prince George's County). 44, On February 23, 2016, Carraway was charged by federal criminal complaint with eight counts of producing child pornography, pursuant to 18 U.S.C. § 2251. See United States ofAmerica v. Deonte Carraway, Case No.: CBD-16-449 (United States District Court for the District of Maryland). 45. As a direct and proximate result of Defendants’ actions, Plaintiffs suffered damages, including but not limited to, emotional harm and distress, emotional trauma, humiliation, embarrassment, loss of privacy, mental pain and suffering, fright, nervousness, indignity, andinsult, Plaintiff John Doe #3 will require psychological counseling and other treatment as a result of this abuse. COUNTI Violation of 18 U.S.C. § 22524 (Plaintiffs v, Defendants Board of Education and Carraway) 46. Plaintiff's sue the Board of Education and Carraway for cause, claim, damages, and hereby adopt and incorporate by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein. 47. 18 U.S.C. § 2252A prohibits conduct related to, among other things, knowingly possessing, creating, and dist wuting child pornography, 48. Carraway violated 18 U.S.C. § 2252A by knowingly possessing and distributing child pornography by showing videos and pictures to minor students at the school, which depicted John Doe #3 and other students. 49. The Board of Education violated this statute because Carraway acted as an agent of the Board and this status and position of influence, control, and authority conferred by the Board permitted, facilitated, and enabled this conduct to occur. Specifically, during the school day and ‘on school property, the Board gave Carraway access to these elementary age students, The Board gave Carraway a position of influence over these students, The Board gave Carraway control of these students and permitted Carraway to have and use his authority as a teacher's assistant to remove students from classrooms, transport the students to bathrooms, auditoriums, or other locations on school property, and perpetrate this sexual abuse during the school day, which he documented by recording these acts.50, 18 U.S.C. § 2252A(D) provides that “[a}ny person aggrieved by reason of the conduct prohibited under” 18 U.S.C. § 2252A(a) or (b) may commence a civil action to recover compensatory and punitive damages, attorneys’ fees, expert witnesses’ fees, and costs. 51. Asa child depicted in the pornography created, possessed, and distributed by Carraway, John Doe #3 is plainly “aggrieved” by Defendants’ conduct. 52. Asa direct and proximate cause of Carraway’s actions, John Doe #3 suffered and continues to suffer severe emotional and mental distress, anguish, humiliation, embarrassment, fright, shock, pain, discomfort, and anxiety WHE FORE, Plaintiffs request that the Court enter a judgment against Defendants as follows: (A) Awarding Plaintifi’s monetary damages against all Defendants, individually, jointly and severally, in an amount to be determined at trial, but, pursuant to Md. Rule 2-305, the amount sought exceeds $75,000; (B) Awarding Plaintiffs punitive damages in an amount to be determined at trial; (C) Awarding Plaintiffs reasonable attorneys’ fees; (D) Awarding Plaintiff's their costs and expenses in this litigation, including expert witness fees; (E) Awarding Plaintifis equitable and injunctive relief compelling the Defendant Board of Education to monitor school property and institute a formal, meaningful, transparent and timely process to investigate employees and/or agents accused of sexually abusing students; and (F) Awarding such other relief as the Court deems just and proper. COUNT IT Violation of 18 U.S.C, § 2255 (Plaintiffs v. Board of Education and Carraway) 53. Plaintiffs sue the Board of Education and Carraway for cause, claim, damages, and hereby adopt and incorporate by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein.54, 18 U.S.C. § 2255 confers a civil cause of action on minor victims arising out of incidents, of sexual abuse, possession of child pomography, and/or creating child pornography (a) In general.--Any person who, while a minor, was a vietim of a violation of section 1589, 1590, 1591, 2241(c), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal injury as result of such violation, regardless of whether the injury occurred while such person was a minor, may sue in any appropriate United States District Court and shall recover the actual damages such person sustains and the cost of the suit, including a reasonable attorney's fee. Any person as described in the preceding sentence shall be deemed to have sustained damages of no less than $150,000 in value. 55. 18 U.S.C. § 2251 prohibits the sexual exploitation of children. 56. 18 U.S.C. § 2252A prohibits certain activities relating to material constituting or containing child pomography. 57. John Doe #3, who is a minor, was the “victim” of Carraway’s violation of 18 U.S.C. § 2252A (Certain activiti relating to material constituting or containing child pornography) and 18 U.S.C. § 2251 (Sexual exploitation of children) 58. On February 23, 2016, Carraway was charged by federal criminal complaint with eight counts of producing child pornography, pursuant to 18 U.S.C. § 2251. See United States of America v. Deonte Carraway, Case No.: CBD-16-449 (United States District Court for the District of Maryland). 59. The Board of Education violated this statute because Carraway acted as an agent of the Board and this status and position of influence, control, and authority conferred by the Board permitted, facilitated, and enabled this conduct to occur. Specifically, during the school day and on school property, the Board gave Carraway access to these elementary age students, The Board ‘gave Carraway a position of influence over these students. The Board gave Carraway control of these students and permitted Carraway to have and use his authority as a teacher's assistant toremove students from classrooms, transport the students to bathrooms, auditoriums, or other locations on school property, and perpetrate this sexual abuse during the school day, which he documented by recording these acts. Even when John Doe #3 reported this incident to his teacher, the Board’s agent failed to take any corrective action. 60. Asa di and proximate cause of Defendants’ actions, John Doe #3 suffered and continues to suffer severe emotional and mental distress, anguish, humiliation, embarrassment, fright, shock, pain, discomfort, and anxiety. 61. The conduct of Defendants was malicious, willful, and intentional WHEREFORE, Plaintiffs request that the Court enter a judgment against Defendants as follows: (A) Awarding Plaintiff's monetary damages against all Defendants, individually, jointly and severally, in an amount to be determined at trial, but, pursuant to Md. Rule 2-305, the amount sought exceeds $75,000; (B) Awarding Plaintiffs punitive damages in an amount to be determined at trial; (C) Awarding Plaintiffs reasonable attorneys’ fees; (D) Awarding Plaintifis their costs and expenses in this litigation; (B) Awarding Plaintiffs equitable and injunctive relief compelling the Defendant Board of Education to monitor school property and institute a formal, meaningful, transparent and timely process to investigate employees and/or agents accused of sexually abusing students; and (F) Awarding such other relief as the Court deems just and proper. Violation of 42 U.S.C. § 1983 (Plaintiffs v. Defendants Williams and Carraway) 62. Plaintiffs sue Defendants Williams and Carraway for cause, claim, damages, and hereby adopt and incorporate by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein 1363. This cause of action is to redress the deprivation under color of statute, ordinance, regulation, policy, custom, practice or usage of a right, privilege and immunity secured to the plaintiffs by the Fourth and Fourteenth Amendment to the United States Constitution. 64, At all relevant times, Carraway worked as a teacher’s assistant for Defendant Board. 65. Based on the allegations above, Carraway, acting individually and in his official capacity as an agent of Sylvania Woods Elementary School, acted under color of state law and deprived John Doe #3 of clearly established rights protected by the Fourth and Fourteenth Amendments to the U.S, Constitution, 66. Defendants’ actions deprived John Doe #3 of his right under the Fourteenth Amendment t0 bodily int ty and personal security 67. Defendants’ actions deprived John Doe #3 of his right under the Fourteenth Amendment to be free from sexual abuse and/or sexual exploitation by public school employees and/or agents 68. Defendants’ actions deprived John Doe #3 of his rights under the Fourteenth Amendment to be free from a deprivation of liberty without due process of law. 69, Based on the widespread problem of sexual abuse and/or exploitation of students by Caraway at Sylvania Woods Elementary School, before, during, and after the abuse suffered by John Doe #3, Defendants have established customs and/or polices that failed to supervise employees from violating the constitutional rights of students, including the students’ rights to be free from unreasonable searches and seizures, the right to bodily integrity, and the right to personal security, 70, Further, based on the widespread problem of sexual abuse by Carraway at Sylvania Woods Elementary School, Defendants have established customs and/or polices that fail todetect and/or investigate incidents of employee sexual abuse or exploitation of students. This includes, but is not limited to, the failure to thoroughly investigate claims of abuse, the failure to supervise teachers, and the policy of permitting teaching assistants to pull students out of class. 71. Defendants’ actions demonstrated a deliberate indifference and/or tacit approval of the sexual abuse and sexual exploitation of students by Carraway. 72. Defendants have followed these unconstitutional policies and customs with respect to John Doe #3’s treatment and the treatment of other Prince George’s County Public School students, 73. Asa direct and proximate result of the Defendants’ actions, John Doe #3 suffered injuries, and he consciously experienced pain and suffering, humiliation, and embarrassment, all to his detriment. WHE) EFORE, Plaintiffs request that the Court enter a judgment against Defendants as follows: (A) Awarding Plaintiffs monetary damages against all Defendants, individually, jointly and severally, in an amount to be determined at trial, but, pursuant to Md. Rule 2-305, the amount sought exceeds $75,000; (B) Awarding Plaintiffs punitive damages in an amount to be determined at trial; (C) Awarding Plaintiffs reasonable attorneys’ fees; (D) Awarding Plaintiffs their costs and expenses in this litigation; (6) Awarding Plaintiffs equitable and injunctive relief compelling the Defendant Board of Education to monitor school property and institute a formal, used of meaningful, transparent and timely process to investigate employees and/or agents sexually abusing students; and (F) Awarding such other relief as the Court deems just and proper. COUNT IV Title IX of the Education Amendments of 1972, 20 U (Plaintiffs v. Defendant Board of Education) § 168174, Plaintiffs sues the Board of Education for cause, claim, damages, and hereby adopts and incorporates by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein, 75. 20 U.S.C. § 1681 (a) provides that “[nJo person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance[.]” 76. Defendant Board operates Sylvania Woods Elementary School and receives federal funding, 77. John Doe #3 suffered sexual harassment, sexual abuse, and/or sexual exploitation in the form of sexual advances, offensive touching, illegal sexual contact, and sexual exploitation for the purpose of producing a recording of the conduct. This harassment occurred on school property and during school hours. 78. The sexual harassment, sexual abuse, and/or sexual exploitation created a hostile, abusive, intimidating, and offensive educational environment at Sylvania Woods Elementary School. This hostile and abusive environment affected John Doe #3’s ability to participate in school and negatively impacted his psychological well-being 79. The sexual harassment, sexual abuse, and/or sexual exploitation deprived John Doe #3 of equal access to his education and educational opportunities, and it had a negative effect on his ability to participate in his education. 80. John Doe #3 told his teacher, Gwyndolyn McNair, that he had been sexually harassed and abused at school. Despite this, McNair, Principal Williams, and the Board failed to conduct any meaningful investigation or take any meaningful action in response. Despite John Doe #3°s statement to his teacher that “Deonte wanted [name omitted] to hump me,” Carraway waspermitted to continue working at the school, pulling students out of class, and escorting them to various locations within the school building for the purpose of sexually abusing them and recording the abuse with his cell phones. 81. Upon information and belief, Sylvania Woods teachers expressed concern and raised issues to the adminis ation about Carraway’s predatory behavior, but the Board failed to take any meaningful investigation. The Board knew or should have known of Carraway’s sexual harassment and abuse. Despite this actual or constructive knowledge, the Board and its agents were deliberately indifferent and/or tacitly approved of this conduct by fuiling to take any meaningful action, failing to investigate, failing to deter, failing to supervise, and permitting a teacher’ ssistant to pull students out of class. 82. Asa direct and proximate result of the Defendant's violation of John Doe #3s rights under Title IX, John Doe #3 suffered injuries, and he consciously experienced pain and suffering, humiliation, and embarrassment, all to his detriment. WHEREFORE, Plaintiffs request that the Court enter a judgment against Defendants as follows: (A) Awarding Plaintiff's monetary damages against all Defendants, individually, jointly 305, the and severally, in an amount to be determined at trial, but, pursuant to Md. Rule amount sought exceeds $75,000; (B) Awarding Plaintiffs punitive damages in an amount to be determined at trial; (C) Awarding Plaintiffs reasonable attorneys’ fees; (D) Awarding Plaintiffs, their costs and expenses in this litigation; (E) Awarding Plaintiffs equitable and injunctive relief compelling the Defendant Board of Education to monitor school property and institute a formal, meaningful, transparent and timely process to investigate employees and/or agents accused of sexually abusing students; and (F) Awarding such other relief as the Court deems just and proper. 7COUNTV Violation of Article 24 of the Maryland Declaration of Rights (Plaintiffs v. Defendants Board and Carraway) 83. Plaintiff sue the Board of Education and Carraway for cause, claim, damages, and hereby adopt and incorporate by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein 84, Article 24 of the Maryland Declaration of Rights guarantees public school students the right to bodily integrity, personal security, the right to be free from sexual abuse and/or sexual exploitation, and to be free from a deprivation of liberty without due process of law. 85, As detailed above, Carraway’s actions deprived John Doe #3 of his rights under Article 24 of the Maryland Declaration of Rights to bodily integrity and personal security, to be free from sexual abuse and/or sexual exploitation by an agent of the Board, and to be free from a deprivation of liberty without due process of law. 86, Carraway coerced John Doe #3 to engage in a sexual act with another student at school, which Carraway recorded on his cell phone. 87. Carraway also distributed obscene recordings and images to John Doe #3 and other students. 88. As a direct and proximate cause of Carraway’s actions, John Doe #3 suffered and continues to suffer severe emotional and mental distress, anguish, humiliation, embarrassment, fright, shock, pain, discomfort, and anxiety. 89. At all times relevant hereto, Defendants acted with ill-will and malice. In doing the foregoing acts, Carraway was working as an agent of the Board and/or under the color of law. 90. The Board is vicariously liable for Defendant Carraway’s violations of John Doe #3’s rights under Article 24 of the Maryland Declaration of Rights.WHERI FORE, Plaintiffs request that the Court enter a judgment against Defendants as, follows: (A) Awarding Plaintiffs monetary damages against all Defendants, individually, jointly and severally, in an amount to be determined at trial, but, pursuant to Md. Rule 2-305, the amount sought exceeds $75,000; (B) Awarding Plaintifi’s punitive damages in an amount to be determined at trial; (C) Awarding Plaintiffs reasonable attorneys’ fees; (D) Awarding Plaintiffs their costs and expenses in this litigation; (E) Awarding Plaintiffs equitable and injunctive relief compelling the Defendant Board of Education to monitor school property and institute a formal, meaningful, transparent and timely process to investigate employees and/or agents accused of sexually abusing students; and (F) Awarding such other relief as the Court deems just and proper. COUNT VI ion of Article 26 of the Maryland Declaration of Rights (Plaintiffs v. Defendants Board and Carraway) Viol 91, Plaintiffs sue the Board of Education and Carraway for cause, claim, damages, and hereby adopt and incorporate by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein. 92, Article 26 of the Maryland Declaration of Rights guarantees the right to be free from unlawful search or seizure, loss of liberty, and the right to bodily integrity. 93. As detailed above, Carraway’s actions deprived John Doe #3 of his rights under Article 26 of the Maryland Declaration of Rights, including, but not limited to freedom from unlawful search or seizure, loss of liberty, and the right to bodily integrity 94, On at least one occasion, Carraway called John Doe #3 out of class and brought him to the dressing room behind the stage in the school auditorium. He used his status and position of influence, control, and authority to get John Doe #3 to come with him by telling him thatPrincipal Williams wanted to speak with him. Carraway directed another fourth-grade boy to perform a sexual act on John Doe #3 in the dressing room while he recorded this on his cell sing room closed phone and held the door of the dre 95. Asa direct and proximate cause of Carraway’s actions, John Doe #3 suffered and continues to suffer severe emotional and mental distress, anguish, humiliation, embarrassment, fright, shock, pain, discomfort, and anxiety. 96. At all times relevant hereto, Defendant Carraway acted with ill-will and malice, 97. In doing the foregoing acts, Defendant Carraway was working as an agent of the Board and/or under color of law. 98, The Board is vicariously liable for Defendant Carraway’s violations of John Doe #/3°s rights under Article 26 of the Maryland Declaration of Rights. WHEREFORE, Plaintiffs request that the Court enter a judgment against Defendants as follows: (A) Awarding Plaintiffs monetary damages against all Defendants, individually, jointly and severally, in an amount to be determined at trial, but, pursuant to Md. Rule 2-305, the amount sought exceeds $75,000; (B) Awarding Plaintiffs punitive damages in an amount to be determined at trial; (C) Awarding Plaintiffs reasonable attorneys’ fees; (D) Awarding Plaintifis their costs and expenses in this litigation; (E) Awarding Plaintiffs equitable and injunctive relief compelling the Defendant Board of Education to monitor school property and institute a formal, meaningful, transparent and timely process to investigate employees and/or agents accused of sexually abusing students; and (F) Awarding such other relief as the Court deems just and proper. OUNT VI Unlawful Pattern and Practice of Violating of the Maryland Declaration of Rights (Plaintiffs v. All Defendants) 2099, Plaintiffs sues all Defendants for cause, claim, damages, and hereby adopt and incorporate by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein, 100. Carraway’s conduct, including the deprivation of constitutional rights, represents not a single, isolated, accidental, or peculiar event, but occurred in the regular procedures followed by Defendant Board of Education and constitutes a pattern or practice of such conduet 101 Prior to the date of this incident, Defendant Board of Education permitted and tolerated a pattern and practice of unjustified, unreasonable, and illegal sexual abuse to occur by teachers of minor students. 102, Moreover, Defendant Board of Education has failed to properly train and supervise its teachers, educators, and teacher’s assistants, including, but not limited to, Defendant Carraway. The failure to properly train and supervise its teachers, educators, and teacher’s assistants demonstrates a gross disregard for the constitutional rights of the public and the Plaintiffs, and was a proximate cause of Plaintiffs” injuries, 103 Based on the widespread problem of sexual abuse and/or exploitation of students by Carraway at Sylvania Woods Elementary School and Prince George’s County public schools, before, during, and after the abuse suffered by John Doe #3, the Board has established customs and/or polices that failed to supervise employees from violating the constitutional rights of students, including the students’ rights to be free from unreasonable searches and seizures, the right to bodily integrity, the right to be free sexual abuse and/or exploitation, and the right to personal security. The failure to properly supervise its employees demonstrates a gross disregard for the constitutional rights of John Doe #3 and was a proximate cause of John Doe #3's injuries, 21104, Asa proximate result of the aforesaid acts, omissions, systemic flaws, policies, and customs, Defendants deprived John Doe #3 of his rights under the Maryland Declaration of Rights. WHEREFORE, Plaintiffs request that the Court enter a judgment against all Defendants as follows: (A) Awarding Plaintiffs monetary damages against all Defendants, individually, jointly and severally, in an amount to be determined at trial, but, pursuant to Md. Rule 2-305, the amount sought exceeds $75,000; (B) Awarding Plaintiffs punitive damages in an amount to be determined at trial; (C) Awarding Plaintiffs reasonable attorneys’ fees; (D) Awarding Plaintifts their costs and expenses in this litigation; (E) Awarding Plaintiffs equitable and injunctive relief compelling the Defendant Board of Education to monitor school property and institute a formal, meaningful, transparent and timely process to investigate employees and/or agents accused of sexually abusing students; and (F) Awarding such other relief as the Court deems just and proper. COUNT Vil Negligent Supervision (Plaintiffs v. Defendant Board of Education) 105. Plaintiffs sue the Board of Education for cause, claim, damages, and hereby adopt and incorporate by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein. 106. Defendant Board owed John Doe #3 a duty to supervise and retain competent teacher assistants, employees, and other individuals present on school grounds, 107. At all relevant times, Carraway worked as a teacher’s assistant at Sylvania Woods Elementary School, 22108 ‘Carraway sexually abused students, coerced students to engage in sexual acts with each other, and recorded the sexual abuse on schoo! property during school hours beginning in early 2015, if not before. 109. Upon information and belief, prior to the sexual abuse and exploitation of John Doe #3, teachers at Sylvania Woods Elementary School expressed concern to Principal Williams concerning Carraway’s behavior. 110. Defendant Board breached its duty to supervise its staff by failing to adequately supervise the workplace despite the fact that it knew, or should have known, that Carraway sexually abused and exploited students. This failure to supervise includes, but is not limited to, the failure to thoroughly investigate the concems from teachers concerning Carraway’s behavi the failure to supervise Carraway, and permitting a teacher's aide to pull students out of class. i Upon information and belief, teachers had knowledge of the sexual abuse and expressed concern and raised issues to the administration about Carraway’s predatory behavior, but the Board failed to take any meaningful investigation, 112. Asa direct and proximate result of the acts and conduet of Carraway, John Doe #3 suffered and continues to suffer severe emotional and mental distress, anguish, humiliation, sment, fright, shock, pain, discomfort, and an: embarra: iy. WHEREFORE, Plaintiffs request that the Court enter a judgment against Defendant Board of Education as follows: (A) Awarding Plaintiff's monetary damages against all Defendants, individually, jointly and severally, in an amount to be determined at trial, but, pursuant to Md, Rule 2-308, the amount sought exceeds $75,000; (B) Awarding Plaintifts punitive damages in an amount to be determined at trial; (C) Awarding Plaintiffs reasonable attorneys’ fees; (D) Awarding Plait iff their costs and expenses in this litigations (E) Awarding 23Plaintifis equitable and injunctive relief compelling the Defendant Board of Education to monitor school property and institute a formal, meaningful, transparent and timely process to inves gate employees and/or agents accused of sexually abusing students; and (F) Awarding such other relief as the Court deems just and proper. COUNT IX Intentional Infliction of Emotional Distress (Plaintiffs v. Defendants Board of Education and Carraway) 113 Plaintiffs sue the Board of Education and Carraway for cause, claim, damages, and hereby adopt and incorporate by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein. 14. John Doe #3 currently attends Sylvania Woods Elementary School. At all relevant times, he was under the care, custody, and control of Defendant Board, its agents, servants, and employees, including Carraway. 115, Defendant Board has a loco parentis relationship with its students and has a special duty to protect a student from harm. 116, Defendants intentionally inflict emotional distress on John Doe #3 through Carraway’s sexual abuse and exploitation of John Doe #3. 117, Carraway, acting individually and in his official capacity as a public school employee, engaged in conduct that was intentional, reckless, and in deliberate disregard of a high degree of probability that emotional distress would result to John Doe #3. Specifically, he pressured and/or coerced John Doe #3 to engage in a sexual act with another fourth-grade student in the school auditorium during school hours while Carraway directed them and recorded the act on his phone.118, Carraway knew or should have known that sexually exploiting John Doe #3 and other young children by a trusted adult would result in extreme emotional distress to that child. 119. Carraway’s actions of sexually exploiting John Doe #3 constituted behavior so outrageous in character and so extreme in degree that it went beyond all possible bounds of decency and constitutes behavior intolerable in a civilized community. 120. The conduct of Carraway was malicious, willful, and intentional. 121 Asa direct and proximate result of the acts and conduct of Carraway, John Doe #3 suffered and continues to suffer severe emotional and mental distress, anguish, humiliation, embarrassment, fright, shock, pain, discomfort, and anxiety. WHEREFORE, Plaintiff’ request that the Court enter a judgment against Defendants as follows: (A) Awarding Plaintiffs monetary damages against all Defendants, individually, jointly and severally, in an amount to be determined at trial, but, pursuant to Md, Rule 2-305, the amount sought exceeds $75,000; (B) Awarding Plaintiffs punitive damages in an amount to be determined at trial; (C) Awarding Plaintiffs reasonable attorneys’ fees; (D) Awarding Plaintiffs, their costs and expenses in this litigation; (E) Awarding Plaintiff’ equitable and injunctive relief compelling the Defendant Board of Education to mor ‘or school property and institute a formal, meaningful, transparent and timely process to investigate employees and/or agents accused of sexually abusing students; and (F) Awarding such other relief as the Court deems just and proper. COUNT X Invasion of Privacy - Intrusion Upon Seclusion (Plaintiffs v. Defendants Board of Education and Carraway)122, Plaintiffs sue the Board of Education and Carraway for cause, claim, damages, and hereby adopt and incorporate by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein. 123. Carraway intentionally recorded video and took photographs of John Doe #3 and other children at Sylvania Woods Elementary School. 124, ‘The videos and pictures depict John Doe #3 and other students performing sexual acts on each other. 125, The videos and pictures are of a highly sensitive nature as they show children as young as nine years old being sexually assaulted. 126. Carraway’s actions in recording and possessing these images violated John Doe #3’s reasonable expectations of privacy 127, Carraway’s actions in recording and possessing the images would be highly offensive to a reasonable person. 128, As a direct and proximate result of the acts and conduct of Carraway, Plaintiffs have suffered and continues to suffer severe emotional and mental distress, anguish, humiliation, embarrassment, fright, shock, pain, discomfort, and anxiety. 129. The conduct of Carraway was malicious, willful, and intentional. WHEREFORE, Plaintiffs request that the Court enter a judgment against Defendants as follows: (A) Awarding Plaintiffs monetary damages against all Defendants, individually, jointly and severally, in an amount to be determined at trial, but, pursuant to Md. Rule 2-305, the amount sought exceeds $75,000; (B) Awarding Plaintiffs punitive damages in an amount to be determined at trial; (C) Awarding Plaintiffs reasonable attorneys’ fees; (D) Awarding Plaintiffs their costs and expenses in this litigation; (E) Awarding Plaintiffs equitable and injunctive relief 26compelling the Defendant Board of Education to monitor school property and institute a formal, meaningful, transparent and timely process to investigate employees and/or agents accused of sexually abusing students; and (F) Awarding such other relief as the Court deems just and proper. ‘T XI Battery (Plaintiffs v. Defendant Carraway) 130, Plaintiffs sue Defendant Carraway for cause, claim, damages, and hereby adopt and incorporate by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein. 131. Defendant Carraway intentionally caused John Doe #3 to be touched in a harmful and offensive manner. Specifically, Defendant Carraway directed John Doe #3 to perform a sex act with another student from his fourth grade class. 132, John Doe #3 did not and could not consent to the offensive touching that Defendant Carraway caused to occur. 133 Defendant Carraway’s actions were undertaken deliberately, with ill-will and actual malice. 134. As a direct and proximate result of Carraway’s battery, John Doe #3 suffered physical and emotional damages, to include conscious pain and suffering. 135. tall times relevant to this Complaint, Carraway was acting within the scope of his duties and responsibilities choir director and/or agent of the City. WHEREFORE, Plaintiffs request that the Court enter a judgment against Defendants as follows: (A) Awarding Plaintiffs monetary damages against all Defendants, individually, jointly and severally, in an amount to be determined at trial, but, pursuant to Md. Rule 2-305, theamount sought exceeds $75,000; (C) Awarding Plaintiffs punitive damages in an amount to be determined at trial; (D) Awarding Plaintiffs reasonable attorneys” fees; (E) Awarding Plaintiffs their costs and expenses in this litigation, including expert witness fees; (F) Awarding Plaintifts equitable and injunetive relief compelling the Defendant City of Glenarden to monitor government property and institute a formal, meaningful, transparent and timely process to investigate employees and/or agents accused of sexually abusing students; and (G) Awarding, Plaintiffs such other relief as the Court deems just and proper. COUNT XII Negligence ~ Violation of Mandatory Reporting Law (Plaintiffs v. Defendants Board and MeNair) 136. Plaintiffs sue the Board of Education and MeNair for cause, claim, damages, and hereby adopt and incorporate by reference the allegations contained in all of the paragraphs of this Complaint as though set forth fully herein. 137. Defendants Board and MeNair owed a duty of care to the children at Judge Sylvania Woods Elementary School. Specifically, the schoo! and its teachers stand in loco iren in their custody and care, Additionally, F.L. § 5-704 imposes a duty on parentis with chil educators to notify the appropriate authorities “as soon as possible” and submit a “written report within 48 hours if the educator has “reason to believe that a child has been subjected to abuse or neglect.” 138. Defendants Board and MeNair breached this duty of care when John Doe #3 told his teacher McNair that “Deonte wanted [name omitted] to hump me,” and she responded by stating “I don’t believe you. Go sit down.” Defendant Board and McNair further breached this duty of care when they declined to make any further inquiries about John Doe #3’s statements such as inquiring as to the location of the other student who was not in the room, by failing to 28question Deonte Carraway about this incident, and by declining to do anything except reprimand John Doe #3. Based on John Doe #3°s statement, Defendants had “reason to believe that a child has been subjected to abuse or neglect” yet Defendants tragically did nothing, 139. Upon information and belief, there is a practice and culture within the Prine George’s County Board of Education to shirk mandatory reporting obligations under F.L. § 5- 704 as it relates to teachers having sexual contact with students. Specifically, this practice and culture results from teachers’ reluctance to report their colleagues and other individuals ~ in violation of F.L. § 5-704 ~ in the school unless they have personal knowledge of the abuse, ie., the individual personally sees the abuse occur. Upon information and belief, this practice and culture results in teachers and educators regularly declining to report instances of “abuse or neglect” by fellow teachers when they have a legal obligation to do so, which occurred here, 140. Upon and information and belief, John Doe #3" report of Deonte Carraway sexual misconduct was not the first report of this activity 141 FLL. § 5-704 is designed to protect a specific class of persons, which includes John Doe #3, Defendants violation of F.L. § 5-704 proximately caused John Doe #3°s injuries. 142, ‘Asa direct and proximate result of Defendants’ actions, John Doe #3 suffered physical and emotional damages, to include conscious pain and suffering WHEREFORE, Plaintiffs request that the Court enter a judgment against Defendants as, follows: (A) Awarding Plaintifi’s monetary damages against all Defendants, individually, jointly and severally, in an amount to be determined at trial, but, pursuant to Md. Rule 2-305, the amount sought exceeds $75,000; (C) Awarding Plaintiffs punitive damages in an amount to be determined at trial; (D) Awarding Plaintiffs reasonable attorneys” fees; (E) Awarding Plaintifis their costs and expenses in this litigation, including expert witness fees; (F) Awarding Plaintiffs 29equitable ani injunctive relief compelling the Defendant City of Glenarden to monitor government property and institute a formal, meaningful, transparent and timely process to investigate employees and/or agents accused of sexually abusing students; and (G) Awarding, Plaintiffs such other relief as the Court deems just and proper. JURY DEMAND, Plaintiffs demand a jury trial as to all claims so triable. By: By: Respectfully submitted, i J (pe Timothy F. Maloney Matthew M. Bryant Alyse L. Prawde JOSEPH, GREENWALD & LAAKE, P.A 6404 Ivy Lane, Suite 400 Greenbelt, Maryland 20770 301/220-2200 (tel.) 301/220-1214 (fax) David Simpson, Esq. - David M. Simpson, P.A. 6404 Ivy Lane, Suite 408 Greenbelt, MD 20770 Phone: (301) 474-9634 Fax: (301) 474-7601 30IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND JANE DOE #3, INDIVIDUALLY AND AS PARENT AND NEXT FRIEND OF JOHN DOE #3, A MINOR clo Joseph, Greenwald & Laake, P.A. 6404 Ivy Lane, Suite 400 Greenbelt, MD 20770 Plaintiffs, PRINCE GEORGE’S COUNTY BOARD OF EDUCATION Serve or Kevin M. Maxwell Chief Executive Officer Case No.: CAL 16- Sasscer Administration Building 14201 School Lane Upper Marlboro, MD 20772 and PRINCIPAL MICHELLE WILLIAMS 3000 Church Street Glenarden, MD 20706 and GWYNDOLYN MCNAIR 3000 Church Street Glenarden, MD 20706 and DEONTE LAVELL CARRAWAY 7930 Glenarden Parkway, Apt. 514 Lanham, MD 20706Defendants. LINE Please issue a summons to the above-named Defendants and return to counsel for Plaintiffs for service by private process server. By: Respectfully submitted, Fimothy F. Maloney Matthew M. Bryant Alyse L. Prawde JOSEPH, GREENWALD & LAAKE, P.A. 6404 Ivy Lane, Suite 400 Greenbelt, Maryland 20770 301/220-2200 (tel.) 301/220-1214 (fax) Yeah. Mobs —ason_/nr Di javid Simpson, Esq. David M. Simpson, P.A. 6404 Ivy Lane, Suite 408 Greenbelt, MD 20770 Phone: (301) 474-9634 Fax: (301) 474-7601 32,