Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 1 of 23

KLINE & SPECTER, P.C.

BY: Thomas R. Kline, PA ID# 28895
David K. Inscho, PA ID# 90267
Lorraine H. Donnelly, PA ID# 93352
1525 Locust Street, Nineteenth Floor
Philadelphia, PA 19102
(215) 772-1000
Attorneys for Plaintiffs
______________________________________________________________________________

IN THE COURT OF UNITED STATES DISTRICT COURT FOR THE MIDDLE

DISTRICT OF PENNSYLVANIA

KELLY CHINEA AND JULIO CHINEA, as

Parents and Natural Guardians of S.C., a minor,
c/o Kline & Specter, PC No. 4:22-cv-00134-MWB
1525 Locust Street, 19th Floor
Philadelphia, PA 19102 (Removed from the Court of Common
Plaintiffs, Pleas of Centre County, Pennsylvania at
Docket No. 2021-3086)
v.

WOODWARD CAMP, INC.

d/b/a WOODWARD GYMNASTICS CAMP AMENDED COMPLAINT
a/k/a WOODWARD U
134 Sports Camp Drive
Woodward, PA 16886 JURY TRIAL DEMANDED
and
WOODWARD PENNSYLVANIA, LLC, f/k/a
POWDR – WOODWARD PA, LLC
134 Sports Camp Drive
Woodward, PA 16886
and
POWDR – WOODWARD CAMPS, LLC
134 Sports Camp Drive
Woodward, PA 16886
and
POWDR – WOODWARD HOLDINGS, LLC
134 Sports Camp Drive
Woodward, PA 16886
and
WOODWARD CAMP PROPERTIES, INC.
134 Sports Camp Drive
Woodward, PA 16886
and

1
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 2 of 23

THE WOODWARD FOUNDATION

134 Sports Camp Drive
Woodward, PA 16886
and
SPORTS MANAGEMENT GROUP, INC. d/b/a
WOODWARD GYMNASTICS CAMP
134 Sports Camp Drive
Woodward, PA 16886
and
NATHANIEL SINGER
89 PLYMPTON STREET, APT. 8
MIDDLEBORO, MA 02346-2628
and
BRITTANY SHULMAN
237 E. Whitehall Rd
State College, PA 16801

Defendants.

AMENDED CIVIL ACTION COMPLAINT AND JURY DEMAND

Plaintiffs, Kelly Chinea and Julio Chinea, as Parents and Natural Guardians of S.C., a

minor, by and through their undersigned counsel, Kline & Specter, hereby file this Amended

Complaint, and complains of the above captioned Defendants as follows:

1. This Complaint arises from the sexual assault of minor Plaintiff S.C. while at

Woodward Gymnastics Camp by then coach Nathaniel Singer, who was placed in a position of

power and authority over minor Plaintiff S.C. by the co-Defendants, collectively referred to as

“Woodward Camp Defendants.”

PARTIES AND VENUE

2. Plaintiffs Kelly Chinea and Julio Chinea, are Parents and Natural Guardians of

S.C., a minor, and residents of the city of Westmont, in DuPage County in Illinois.

3. Minor Plaintiff’s full name is not contained in this pleading to protect her privacy

since she is a minor and the victim of a sexual assault, and done in good faith to avoid additional

2
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 3 of 23

embarrassment and psychological harm. Minor Plaintiff’s identity is being made known to

Defendants by separate communication.

4. Defendant, Woodward Camp, Inc. d/b/a Woodward Gymnastics Camp a/k/a

Woodward U, is a corporation and/or business entity organized under the laws of Pennsylvania

with a principal place of business at 134 Sports Camp Drive, Woodward, PA 16886, which at all

relevant times was in the business of operating, managing, marketing, and/or overseeing a global

sports company that boasts state of the art facilities and programs to many of the world’s top

action sports and gymnastics athletes, including current and future Olympians, with multiple

locations throughout the United States, Mexico and China, including a gymnastics camp known

as “Woodward Gymnastics Camp” located at 134 Sports Camp Drive, Woodward, PA 16886.

5. Woodward Pennsylvania, LLC f/k/a POWDR – Woodward PA, LLC is a

corporation and/or business entity organized under the laws of Delaware with a principal place of

business at 134 Sports Camp Drive, Woodward, PA 16886, which at all relevant times was in the

business of operating, managing, marketing, and/or overseeing a global sports company that

boasts state of the art facilities and programs to many of the world’s top action sports and

gymnastics athletes, including current and future Olympians, with multiple locations throughout

the United States, Mexico and China, including a gymnastics camp known as “Woodward

Gymnastics Camp” located at 134 Sports Camp Drive, Woodward, PA 16886.

6. Defendant, Powdr – Woodward Camps, LLC, is a corporation and/or business

entity organized under the laws of Delaware with a principal place of business at 134 Sports

Camp Drive, Woodward, PA 16886, which at all relevant times was in the business of operating,

managing, marketing, and/or overseeing a global sports company that boasts state of the art

facilities and programs to many of the world’s top action sports and gymnastics athletes,

3
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 4 of 23

including current and future Olympians, with multiple locations throughout the United States,

Mexico and China, including a gymnastics camp known as “Woodward Gymnastics Camp”

located at 134 Sports Camp Drive, Woodward, PA 16886.

7. Defendant, Powdr – Woodward Holdings, LLC, is a corporation and/or business

entity organized under the laws of Delaware with a principal place of business at 134 Sports

Camp Drive, Woodward, PA 16886, which at all relevant times was in the business of operating,

managing, marketing, and/or overseeing a global sports company that boasts state of the art

facilities and programs to many of the world’s top action sports and gymnastics athletes,

including current and future Olympians, with multiple locations throughout the United States,

Mexico and China, including a gymnastics camp known as “Woodward Gymnastics Camp”

located at 134 Sports Camp Drive, Woodward, PA 16886.

8. Defendant, Woodward Camp Properties, Inc., is a corporation and/or business

entity organized under the laws of Pennsylvania with a principal place of business at 134 Sports

Camp Drive, Woodward, PA 16886, which at all relevant times was in the business of operating,

managing, marketing, and/or overseeing a global sports company that boasts state of the art

facilities and programs to many of the world’s top action sports and gymnastics athletes,

including current and future Olympians, with multiple locations throughout the United States,

Mexico and China, including a gymnastics camp known as “Woodward Gymnastics Camp”

located at 134 Sports Camp Drive, Woodward, PA 16886.

9. Defendant, The Woodward Foundation, is a corporation and/or business entity

organized under the laws of Pennsylvania with a principal place of business at 134 Sports Camp

Drive, Woodward, PA 16886, which at all relevant times was in the business of operating,

managing, marketing, and/or overseeing a global sports company that boasts state of the art

4
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 5 of 23

facilities and programs to many of the world’s top action sports and gymnastics athletes,

including current and future Olympians, with multiple locations throughout the United States,

Mexico and China, including a gymnastics camp known as “Woodward Gymnastics Camp”

located at 134 Sports Camp Drive, Woodward, PA 16886.

10. Defendant, Sports Management Group, Inc. d/b/a Woodward Gymnastics Camp is

a corporation and/or business entity organized under the laws of Pennsylvania with a principal

place of business at 134 Sports Camp Drive, Woodward, PA 16886, which at all relevant times

was in the business of operating, managing, marketing, and/or overseeing a global sports

company that boasts state of the art facilities and programs to many of the world’s top action

sports and gymnastics athletes, including current and future Olympians, with multiple locations

throughout the United States, Mexico and China, including a gymnastics camp known as

“Woodward Gymnastics Camp” located at 134 Sports Camp Drive, Woodward, PA 16886.

11. At all relevant times hereto, Defendants, Woodward Camp, Inc. d/b/a Woodward

Gymnastics Camp a/k/a Woodward U; Powdr – Woodward Pa, LLC; Powdr – Woodward

Camps, LLC; Powdr – Woodward Holdings, LLC; Woodward Camp Properties, Inc.; The

Woodward Foundation; Sports Management Group, Inc. d/b/a Woodward Gymnastics Camp

(hereinafter “Woodward Camp Defendants”) individually, collectively, and/or through joint

venture owned, operated, managed, marketed, and controlled a global sports company that boasts

state of the art facilities and programs to many of the world’s top action sports and gymnastics

athletes, including current and future Olympians, with multiple locations throughout the United

States, Mexico and China, including a gymnastics camp known as “Woodward Gymnastics

Camp” located at 134 Sports Camp Drive, Woodward, PA 16886.

5
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 6 of 23

12. Defendant, Nathaniel Singer, is an adult individual residing at 89 Plympton Street,

Apt. 8 Middleboro, MA 02346-2628.

13. At all relevant times herein, Defendant Nathaniel Singer was a gymnastics coach

at Woodward Camp Defendants’ gymnastics camp known as “Woodward Gymnastics Camp”

located at 134 Sports Camp Drive, Woodward, PA 16886, and employed by the Woodward

Camp Defendants.

14. Defendant Brittany J. Shulman (nee Epps) is an adult individual residing at 237 E.

Whitehall Road, State College, PA 16801.

15. At all relevant times herein, Defendant Brittany Shulman was an administrator at

the Woodward Gymnastics Camp and in charge of, among other things, the hiring, retention and

supervision of the personnel for the camp, including Nathaniel Singer.

16. At all times relevant herein, the Woodward Camp Defendants were acting by and

through its officers, employees, servants, and agents including Matt Lea, Brittany Shulman,

Gregory Frew, Pamela Velasquez, and Elizabeth Price, in the operation of the gymnastics camp

known as “Woodward Gymnastics Camp” located at 134 Sports Camp Drive, Woodward, PA

16886, and the hiring, admitting, assigning, retaining, and supervising of employees, agents,

servants, and coaches, including Defendant Nathaniel Singer.

17. Accordingly, the Woodward Camp Defendants are not only directly liable for

their own negligence, but also vicariously liable for the negligent acts and omissions of their

employees, servants, agents, and coaches while engaged in the operation of the Woodward

Gymnastics Camp, including Defendant Nathanial Singer, Matt Lea, Brittany Schulman, and

Elizabeth Price, under theories of respondeat superior, master-servant, agency, and/or vicarious

liability.

6
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 7 of 23

18. Defendants are jointly and severally liable to Plaintiffs.

19. Plaintiffs initiated this cause of action by filing a Complaint in Centre County,

Pennsylvania, on December 21, 2021.

20. Venue is properly laid in Centre County, Pennsylvania, pursuant to Pa.R.C.P.

1006 & 2156, as the cause of action arose in said county and Defendants’ principal place of

business and in which it regularly conducts business are in Centre County, Pennsylvania.

21. On January 25, 2022, Defendant Woodward Pennsylvania, LLC f/k/a POWDR –

Woodward PA, LLC removed this case from the Court of Common Pleas of Centre County

Pennsylvania to the United States District Court for the Middle District of Pennsylvania.

22. Plaintiffs file this Amended Complaint pursuant to F.R.C.P. 15(a)(1)(B).1

FACTS GIVING RISE TO THE ACTION

23. The previous paragraphs are incorporated herein by reference.

24. The Woodward Camp Defendants offer an overnight, twelve-week summer

gymnastics camp located at 134 Sports Camp Drive, Woodward, PA 16886 (hereinafter

“Woodward Gymnastics Camp”), and promised skilled instructors and coaches who were “the

best in the country” who “meet our high standards” and also promised instruction from special

guest Olympians.

25. The Woodward Camp Defendants also marketed that they put “safety first” at

their gymnastics camp and recommended at least a two week stay at their facility that offered

room and board.

1
Plaintiffs are also filing a Motion to Remand in this matter under separate cover because it was improperly
removed.

7
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 8 of 23

26. The Woodward Camp Defendants described their typical day at the Woodward

Gymnastics overnight camp to include instruction and activities intermixed with dining and

recreational activities all from 7:30am until 10pm.

27. In the summer of 2016, Woodward Camp Defendants employed Defendant

Nathaniel Singer as one of the gymnastics coaches at the camp. He also worked as a disc-jockey

(DJ) at the camp.

28. Prior to the summer of 2016, Defendant Nathaniel Singer engaged in an intimate

relationship with a minor female gymnast and Woodward Camper.

29. During the summer of 2016, Defendant Nathaniel Singer engaged in several

violations of camp policy with regard to interactions and isolating minor female campers,

including taking them alone on golf cart rides and being alone with them in the D.J. booth.

30. These violations were known and/or should have been known to camp

administrators, including Defendant Brittany Shulman. Ms. Shulman and the other

administrators at Woodward Camp, failed to take any action against Defendant Singer to protect

its minor campers.

31. During the Summer of 2016, Defendant Singer pursued an intimate relationship

with a female minor camper/junior counselor, referred herein as Jane Doe.2 Through the

summer, Singer sent Jane Doe proactive photos of himself over snapchat, including photos of

himself after showering.

32. During the summer of 2016, Defendant Singer snuck Jane Doe out of her cabin in

the middle of the night and sexually abused her on campgrounds.

2
Because this minor camper was a victim of sexual abuse and exploitation by Nathaniel Singer, Plaintiff is utilizing
a pseudonym. Upon information and belief the identity of this victim is known to Defendants, but will be provided
in discovery.

8
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 9 of 23

33. Despite his having engaged in multiple violations of camp policy and having

sexually abused a minor camper, the Woodward Camp Defendants and its administrators,

including Defendant Brittany Shulman, rehired Defendant Singer as a gymnastic coach and DJ in

the summer of 2017.

34. During the summer of 2017, the Junior Camp Director at the Woodward Camp

learned about Defendant’s sexual abuse of Jane Doe the prior summer. He reported the abuse to

Woodward Camp Administrators, including Defendant Shulman.

35. Defendant Singer admitted to Woodward Camp Administrators that he had sexual

contact with the Jane Doe the prior summer when she was a minor camper.

36. The Junior Counselor Director also informed Defendant Shulman that Defendant

Singer had taken another minor camper off of campgrounds alone, another violation of camp

policy.

37. Woodward Administrators, including Defendant Shulman, failed to fire and

remove Defendant Singer from the camp upon learning of his sexual abuse the prior summer and

his repeated violations of camp policy in isolating and being alone with minor campers.

38. Prior to the summer of 2018, the Woodward Camp Defendants and its

administrators, including Defendant Brittany Shulman, rehired Nathaniel Singer as a gymnastics

coach and D.J. at the camp, despite knowing about his sexual abuse on Jane Doe in the summer

of 2016 and his repeated violations of camp policy.

39. Defendant Shulman participated in the rehiring of Defendant Singer for the

summer of 2018, despite knowing about his sexual abuse of Jane Doe, his repeated violations of

camp policy, and the danger he posed to campers.

9
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 10 of 23

40. The Junior Counselor Director who had previously reported Defendant Singer’s

sexual abuse and violations of camp policy, suggested to Defendant Shulman that Defendant

Singer’s interactions with minor campers be limited to protect them from Defendant Singer.

Defendant Shulman and other Woodward Camp Administrators refused to do so.

41. S.C. attended the Woodward Gymnastics Camp for week nine (9) of the 2017

summer camp without incident. Upon information and belief, Defendant Singer was not at

Woodward that week.

42. S.C. attended the Woodward Gymnastics Camp for weeks nine (9) and ten (10) in

the summer of 2018. She was thirteen (13) years old that summer.

43. Despite the Woodward Camp Administrators and Defendant Shulman knowing

about Defendant Singer’s history and danger he posed to minor campers, Singer was assigned as

one of S.C.’s coaches.

44. During week 10 of the 2018 summer camp, which was Saturday August 4, 2018

through Saturday August 11, 2018, Defendant Nathanial Singer began grooming S.C. by

improperly touching her buttocks while spotting her during gymnastics activities.

45. During the same week, Defendant Nathanial Singer progressed to slipping his

finger into S.C.’s leotard and into her vagina while he spotted her on the bars and during a bar

drill.

46. S.C. did not report Defendant Nathanial Singer to anyone because she was scared.

S.C. did not know that the Woodward Camp Administrators were already aware of Defendant

Singer’s propensity to abuse minor female campers.

10
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 11 of 23

47. Prior to the summer of 2019, the Woodward Camp Defendants again rehired

Defendant Singer as a gymnastics coach and D.J. at the camp, despite knowing about his sexual

abuse on Jane Doe in the summer of 2016 and his repeated violations of camp policy.

48. Defendant Shulman again participated in the rehiring of Defendant Singer for the

summer of 2019, despite knowing about his sexual abuse of Jane Doe, his repeated violations of

camp policy, and the danger he posed to campers.

49. In the Summer of 2019, the Junior Counselor Director who had previously

reported Defendant Singer’s sexual abuse and violations of camp policy, again informed

Woodward Camp Administrators, including Defendant Shulman and Pam Velasquez, that Singer

posed a danger to the kids at the camp. Defendant Shulman stated that she was fine with

Defendant Singer working at the camp despite his past “mistakes.” Defendant Shulman and

other Woodward Camp Administrators again failed to limit Singer’s interaction with minor

campers.

50. In the summer of 2019, S.C. returned to Woodward Gymnastics Camp for week

nine (9) of the twelve-week program, and Defendant Nathanial Singer was again one of the

gymnastics coaches and DJ’s. S.C. was fourteen years old at that time.

51. During week 9 of 2019 summer camp, Defendant Nathanial Singer again

improperly touched S.C.’s buttocks during spotting and in open gym.

52. During the same week, Defendant Nathanial Singer again progressed to slipping

his finger into S.C.’s leotard and into her vagina while he spotted her on the bars.

53. This time S.C. said to Defendant Nathanial Singer, “you spotted me weird.”

Defendant Nathanial Singer replied, “that is how I spot this drill.”

11
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 12 of 23

54. That same week, Defendant Nathanial Singer again slipped his finger into S.C.’s

leotard and into her vagina while spotting her.

55. Later that same week, Defendant Nathanial Singer tried to corner S.C. in a

hallway and close the door, but S.C. was able to push the door open and walk back out the beam

area where other coaches were located.

56. That same week, Defendant Nathanial Singer tried for a second time to corner

S.C. alone in a hallway but S.C. was able to push past him and get away.

57. S.C. reported to head coach Matt Lea that Coach Nathanial Singer was spotting

her inappropriately and that he made her uncomfortable.

58. Coach Matt Lea reported S.C.’s allegations about Coach Nathanial Singer to the

Defendant Schulman, and her assistant, Elizabeth Price.

59. S.C. then reported to Defendant Shulman, and her assistant, Elizabeth Price that

Coach Nathanial Singer was spotting her inappropriately, that he made her uncomfortable, and

that it hurt her when he did it.

60. Rather than provide assistance to this 14-year-old girl who reported being

sexually assaulted by one of the Woodward Gymnastics Camps coaches, Elizabeth Price and

Brittany Shulman secluded S.C. alone in a conference room and interrogated S.C. about the

report of abuse, challenged her credibility, and advised her not to ruin Nathanial Singer’s

reputation and to stop spreading rumors. They also threatened that if she continued to talk about

Singer’s assault that it would wreck her chance of being a gymnast in college.

61. Defendant Shulman’s treatment of S.C. after she reported Singer’s abuse, while in

a position of power over S.C., who was a minor girl, and while knowing that Singer had actually

abused minor campers in the past, was extreme and outrageous.

12
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 13 of 23

62. S.C. suggested that coach Brittany Schulman, and Elizabeth Price review the

camera footage at the facility as there were cameras everywhere, but they claimed that they were

already recorded over.

63. Head coach Matt Lea, Defendant Schulman, and Elizabeth Price were all

mandatory reporters, but failed to report S.C.’s allegations of sexual abuse to the police or other

law enforcement.

64. S.C. also witnessed Nathanial Singer use inappropriate spotting techniques by

touching the buttocks of other girls at Woodward Gymnastics camp in 2018 and 2019.

65. Other campers also discussed that Singer was inappropriate generally and in the

way he spotted them.

66. Other coaches and staff at Woodward Camp, beyond those discussed above, were

concerned about Singer’s behavior with campers and raised issues with camp administrators,

including Defendant Shulman, prior the assaults on S.C.

67. Defendant Nathanial Singer was suspended for sexual misconduct by USA

Gymnastics and/or the U.S. Center for SafeSport as of July of 2020 and given a “no contact

directive” as of May 27, 2021.

68. Upon information and belief, the reason Defendant Nathanial Singer was

suspended was because he had an inappropriate sexual relationship with a minor camper prior

Singer’s abuse of S.C.

69. Despite being aware of the report of sexual abuse committed by coach Nathanial

Singer on S.C., a minor, the Woodward Camp Defendants continued to disregard this known

risk, and failed to act to protect children, including S.C.

13
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 14 of 23

70. In addition to failing to act, the Woodward camp Defendants and its leadership,

including Defendant Shulman, failed to report the sexual abuse to law enforcement authorities,

thus facilitating sexual abuse of children.

71. The negligence, recklessness, and outrageous conduct of Defendant Nathanial

Singer, Defendant Shulman, and the Woodward Camp Defendants and their agents and/or

employees was a factual cause of S.C.’s harm and was a substantial factor in causing and did

directly proximately cause the severe, permanent, and grievous injuries and damages, including:

a. Mental anguish, humiliation, pain, suffering, and emotional trauma from

being sexually assaulted as a child;

b. Additional mental anguish, pain, suffering, humiliation, and emotional trauma

from being sexually assaulted by an adult coach of a sport that S.C. loved and
excelled in, with potential to obtain gymnastics scholarships for college;

c. Additional mental anguish, pain, suffering, humiliation, and emotional trauma

from being interrogated, shamed, and threatened by other adults in positions
of authority and power at the Woodward Gymnastics Camp after S.C.
reported the sexual abuse,

d. Additional mental anguish, pain, suffering, humiliation, and emotional trauma

due to the failure of adults in positions of authority and power at the
Woodward Gymnastics Camp to report this allegation of abuse to law
enforcement;

e. Post-Traumatic Stress Disorder (“PTSD”);

f. night terrors;

g. fear;

h. flashbacks;

i. panic attacks;

j. costs associated with mental health treatment;

k. intense psychological distress;

l. past and future economic loss;

14
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 15 of 23

m. past and future embarrassment and humiliation;

n. past and future pain and suffering, mental anguish and loss of life’s pleasures;

o. other physical, economic, and psychological injuries, some of which may be

permanent, arising of the sexual assaults.

72. As set forth more fully below, the negligence, recklessness, and outrageous

conduct of the Defendants was a direct and proximate cause of harm to S.C.

73. Plaintiff S.C.’s injuries were caused solely by the negligence, recklessness, and

outrageous conduct of the Defendants, as set forth more fully herein, and were not caused or

contributed thereto by any negligence on the part of the Plaintiff S.C.

COUNT I - NEGLIGENCE
Plaintiffs v. Defendants, Woodward Camp, Inc. d/b/a
Woodward Gymnastics Camp a/k/a Woodward U; Woodward Pennsylvania, LLC
f/k/a Powdr – Woodward Pa, LLC; Powdr – Woodward Camps, LLC; Powdr –
Woodward Holdings, LLC; Woodward Camp Properties, Inc.; The Woodward
Foundation; Sports Management Group, Inc. d/b/a Woodward Gymnastics Camp
(“Woodward Camp Defendants”) and Defendant Brittany Shulman

74. The previous paragraphs are incorporated herein by reference.

75. The negligence, recklessness, and outrageous conduct of Defendants include:

a. Negligently and/or recklessly failing to observe and supervise coach Nathanial

Singer;

b. Negligently and/or recklessly failing to recognize Nathanial Singer’s conduct

described herein as creating a risk of sexual abuse of children;

c. Negligently and/or recklessly failing to have policies and procedures to require

supervision and observation of coaches, including Nathanial Singer and S.C.;

d. Negligently and/or recklessly failing to identify Nathanial Singer as a sexual

abuser;

e. Negligently and/or recklessly failing to investigate behavior of Nathanial

Singer that put the Woodward Camp Defendants on notice that Nathanial Singer
was a potential pedophile;

f. Negligently and/or recklessly failing to have policies and procedures in place

15
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 16 of 23

to screen coaches, including Nathanial Singer, for the possibility of being sexual
predators;

g. Negligently and/or recklessly failing to remove or suspend Nathanial Singer

from active coaching immediately when S.C. reported the assault;

h. Negligently and/or recklessly allowing Nathanial Singer to continue in active

coaching at the Woodward Camps where he had access and authority over
children;

i. Failure to use reasonable and due care under the circumstances; and

j. Negligence and recklessness as may be proven from facts now exclusively in

the possession of Defendants, which may be ascertained after the filing of this
Complaint.

WHEREFORE, Plaintiffs demand damages, including punitive damages, against

all Defendants, jointly and severally, in an amount in excess of the prevailing arbitration limits,

exclusive of pre-judgment interest, delay damages and costs on all counts.

COUNT II - NEGLIGENT SUPERVISION

Plaintiffs v. Defendants, Woodward Camp, Inc. d/b/a
Woodward Gymnastics Camp a/k/a Woodward U; Woodward Pennsylvania, LLC
f/k/a Powdr – Woodward Pa, LLC; Powdr – Woodward Camps, LLC; Powdr –
Woodward Holdings, LLC; Woodward Camp Properties, Inc.; The Woodward
Foundation; Sports Management Group, Inc. d/b/a Woodward Gymnastics Camp
(“Woodward Camp Defendants”) and Defendant Brittany Shulman

76. The previous paragraphs are incorporated herein by reference.

77. Defendants had a duty to use reasonable care in selecting, supervising, and

controlling employees.

78. Defendants knew that it was placing coaches, including Nathanial Singer, in a

special relationship of trust with children, a vulnerable group, while acting in the course of their

duties at the Woodward Gymnastics Camp.

79. Defendants knew it was placing coaches, including Nathanial Singer, in a position

where they would have the opportunity to commit harm to children, including S.C.

16
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 17 of 23

80. Defendants knew that it had the ability to supervise and control its coaches,

including Nathanial Singer.

81. Prior the abuse of S.C. Defendants knew that Nathaniel Singer had sexually abused

a minor camper and committed multiple violations of camp policy by improperly being along with

and isolating minor-campers.

82. Prior the abuse of S.C. Defendants had been specifically warned of the danger

Singer posed to minor-campers and the need to supervise him.

83. Defendants knew it was in a position to supervise its coaches, including Nathanial

Singer, to prevent further acts of harm and sexual abuse.

84. Defendants knew or should have known that its coaches could harm children,

including S.C., even if acting outside of their coaching duties.

85. The negligence and recklessness of Defendants in the supervision of Nathanial

Singer consist of one or more of the following:

a. Failing to use due care in supervising Nathanial Singer’s interaction with

children;

b. Failing to ensure that Nathanial Singer was not alone with a child and/or
children;

c. Failing to ensure that Nathanial Singer was using appropriate spotting

techniques with the gymnasts;

d. Failing to investigate and supervise Nathanial Singer in light of reports that he

had sexually abused S.C.;

e. Failing to discipline Nathanial Singer;

f. Failing to educate and train Nathanial Singer and other coaches, about
appropriate spotting techniques;

g. Failing to educate and train Nathanial Singer, head coaches, camp

administrators, and other employees about recognizing signs of possible
sexual abuse and a mechanism to report suspected sexual abuse;

17
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 18 of 23

h. Failing to educate campers and gymnasts, including S.C., regarding

appropriate versus inappropriate conduct by adults and coaches and to report
inappropriate behavior to law enforcement;

i. Failing to share with law enforcement reports of sexual abuse within the
Woodward Gymnastics Camp, including Nathanial Singer;

86. Defendants did not attempt to prevent the foreseeable harm, and instead took a

course of conduct that increased the risk that coaches could harm minors, including Nathanial

Singer harming S.C.

87. Defendants actively concealed and/or ignored Nathanial Singer inappropriate and

pedophiliac behaviors.

88. Defendants were in a position to prevent the harm Nathanial Singer inflicted on

S.C., yet failed to prevent such harm.

89. When S.C. reported the sexual abuse of Nathanial Singer to Defendants through

their agents, Defendants compounded the harm by silencing and threatening S.C.

WHEREFORE, Plaintiffs demand damages, including punitive damages, against all

Defendants, jointly and severally, in an amount in excess of the prevailing arbitration limits,

exclusive of pre-judgment interest, delay damages and costs on all counts.

COUNT III - NEGLIGENT HIRING AND RETENTION

Plaintiffs v. Defendants, Woodward Camp, Inc. d/b/a
Woodward Gymnastics Camp a/k/a Woodward U; Woodward Pennsylvania, LLC
f/k/a Powdr – Woodward Pa, LLC; Powdr – Woodward Camps, LLC; Powdr –
Woodward Holdings, LLC; Woodward Camp Properties, Inc.; The Woodward
Foundation; Sports Management Group, Inc. d/b/a Woodward Gymnastics Camp
(“Woodward Camp Defendants”) and Defendant Brittany Shulman

90. The previous paragraphs are incorporated herein by reference.

91. Defendants knew prior to 2018 that S.C. and other young children in its camps

were vulnerable and potential victims of sexual abuse.

18
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 19 of 23

92. Defendants also knew prior to 2018 that the access to vulnerable youths and the

physical contact required by gymnastic coaches when spotting gymnasts makes being

gymnastics coach an enticing vocation to pedophiles and others seeking to abuse and exploit

children.

93. Defendants owed a duty to exercise reasonable care in the selection and retention

of coaches in Woodward Gymnastics Camp, and specifically a duty to remain vigilant with

respect to possible pedophiles and others seeking to abuse and exploit children.

94. Prior to the abuse of S.C., Defendants had actual knowledge that Nathaniel

Singer’s sexual abuse of minor campers, his repeated violations of camp policy in being alone

with and isolating minor campers, and the danger he posed to minor campers.

95. Prior to the abuse of S.C., Defendants were specifically warned by at least one

member of their staff of the danger Nathaniel Singer posed to minor campers.

96. Defendants failed to exercise reasonable care in the selection of and retention of

Nathanial Singer as a gymnastics coach, by among other things, the following:

a. Failing to perform a thorough background check and investigation for its

coaches, including Nathanial Singer;

b. Failing to investigate Nathanial Singer history of sexual impropriety;

c. Failing to investigate whether Nathanial Singer had any inappropriate sexual

interest in minors;

d. Failing to investigate whether Nathanial Singer had a pattern of grooming and

isolating young girls;

e. Failing to use due care in the selection of Nathanial Singer as a gymnastics

coach who would be coaching minors;

f. Failing to use due care in the retention of Nathanial Singer as a gymnastics

coach who would be coaching minors;

19
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 20 of 23

g. Failing to terminate Nathanial Singer and/or remove him from the position of
gymnastics coach after learning of his prior sexual abuse of minor-camper,
repeated violations of camp policy in being alone with and isolating minor
campers, and the danger he posed to minor campers;

h. Rehiring Nathaniel Singer as a Gymnastic Coach for the Summer of 2018

despite knowing of his prior sexual abuse of minor-camper, repeated violations
of camp policy in being alone with and isolating minor campers, and the danger
he posed to minor campers;

i. Rehiring Nathaniel Singer as a Gymnastic Coach for the Summer of 2019

despite knowing of his prior sexual abuse of minor-camper, repeated violations
of camp policy in being alone with and isolating minor campers, and the danger
he posed to minor campers

WHEREFORE, Plaintiffs demand damages against all Defendants, including punitive

damages, jointly and severally, in an amount in excess of the prevailing arbitration limits, exclusive

of pre-judgment interest, delay damages and costs on all counts.

COUNT IV - VICARIOUS LIABILITY

Plaintiffs v. Defendants, Woodward Camp, Inc. d/b/a
Woodward Gymnastics Camp a/k/a Woodward U; Woodward Pennsylvania, LLC
f/k/a Powdr – Woodward Pa, LLC; Powdr – Woodward Camps, LLC; Powdr –
Woodward Holdings, LLC; Woodward Camp Properties, Inc.; The Woodward
Foundation; Sports Management Group, Inc. d/b/a Woodward Gymnastics Camp
(“Woodward Camp Defendants”)

69. The previous paragraphs are incorporated herein by reference.

70. Defendant is vicariously liable for the actions described herein of its agents,

servants, and/or employees, including, but not limited to, Matt Lea, Gregory Frew, Pamela

Velasquez, Elizabeth Price and Defendants Brittany Shulman and Nathanial Singer.

71. The sexual assaults occurred while Nathanial Singer was performing his duties as

a gymnastics coach, including spotting the gymnasts.

72. The sexual assaults occurred while Nathanial Singer was a gymnastics coach at

the Woodward Gymnastics Camp’s overnight summer camp, and thus occurred within the

authorized time and space limits of his employment with the Woodward Camp Defendants.
20
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 21 of 23

73. Defendants were aware of Nathaniel Singer’s prior misconduct with Minor

Campers and his propensity to sexual abuse minor campers.

74. Defendants rehired Nathaniel Singer in the Summer of 2018, knowing of his prior

sexual abuse of campers and ratifying and adopting any conduct by Defendant Singer that may

have otherwise exceeded the scope of his agency.

75. Defendants again rehired Nathaniel Singer in the Summer of 2019, knowing of

his prior sexual abuse of campers and ratifying and adopting any conduct by Defendant Singer

that may have otherwise exceeded the scope of his agency.

76. The actions and/or omissions of Defendants and their agents, servants, and/or

employees and administrators, including Matt Lea, Gregory Frew, Pamela Velasquez, Elizabeth

Price and Defendants Brittany Shulman and Nathanial Singer, were a factual cause of and/or

placed Plaintiff S.C. at an increased risk of harm for and/or was a substantial factor in causing,

and did directly and proximately cause the harm suffered described herein by Plaintiff S.C.

77. Defendants are liable for the negligent conduct of any and all agents, ostensible

agents, servants, and/or employees, including Matt Lea, Gregory Frew, Pamela Velasquez,

Elizabeth Price and Defendants Brittany Shulman and Nathanial Singer as described herein

pursuant to principles of agency, vicarious liability, and/or respondeat superior.

WHEREFORE, Plaintiffs demand damages against all Defendants, jointly and

severally, in an amount in excess of the prevailing arbitration limits, exclusive of pre-judgment

interest, delay damages and costs on all counts.

COUNT V – ASSAULT AND BATTERY

Defendant Nathanial Singer

78. The previous paragraphs are incorporated herein by reference.

21
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 22 of 23

79. The aforementioned conduct by Defendant Nathanial Singer inflicted upon S.C.

while at the Woodward Gymnastics Camp in the summer of 2018 and 2019, constitute sexual

assault and physical battery.

80. As a result of Defendant Nathanial Singer’s repeated acts of sexual assault and

physical battery, S.C. was caused to suffer painful physical, metal, and emotional harm as outlined

above.

WHEREFORE, Plaintiffs demand damages against all Defendants, jointly and severally,

in an amount in excess of the prevailing arbitration limits, exclusive of pre-judgment interest, delay

damages and costs on all counts.

COUNT VI- INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

Plaintiffs v. Defendants, Woodward Camp, Inc. d/b/a
Woodward Gymnastics Camp a/k/a Woodward U; Woodward Pennsylvania, LLC
f/k/a Powdr – Woodward Pa, LLC; Powdr – Woodward Camps, LLC; Powdr –
Woodward Holdings, LLC; Woodward Camp Properties, Inc.; The Woodward
Foundation; Sports Management Group, Inc. d/b/a Woodward Gymnastics Camp
(“Woodward Camp Defendants”) and Defendant Brittany Shulman

81. The preceding paragraphs of this Complaint are incorporated as though fully set

forth therein.

82. Defendants through their agents and employees, Defendant Shulman and other

Woodward Camp Administrators, not only permitted Defendant Singer to sexually abuse her

which they were charged with protecting her, but further traumatized her by interrogating her and

pressuring her to keep quiet about her abuse.

83. Defendants through their agents and employees, Defendant Shulman and other

Woodward Camp Administrators, intentionally inflicted emotional distress on S.C. by

interrogating her without the presence of a parent and using their positions of power and authority

to pressure her to not reveal the allegations against Nathaniel Singer.

22
 Case 4:22-cv-00134-MWB Document 5 Filed 02/09/22 Page 23 of 23

84. Defendant Shulman and the other Camp Administrators secluded and pressured

S.C. despite knowing that Nathaniel Singer had previously sexually abused another minor camper.

85. Defendant Shulman and the other Camp Administrators intentionally manipulated

S.C. into not coming forward regarding the abuse she suffered at Woodward Camp by stating that

the allegations would ruin Defendant Singer’s reputation when they knew Defendant Singer had

previously abused another minor camper and the Woodward Administrators had failed to report

it.

86. Defendant Shulman and the other Camp Administrators intentionally attempted to

cover up the Nathaniel Singer’s abuse of Jane Doe and S.C..

87. The aforementioned conduct of the Woodward Camp Defendants, by and through

Defendant Shulman and other camp administrators was extreme and outrageous.

88. As a direct and proximate result of the intentional conduct of Woodward Camp

Defendants, by and through Defendant Shulman and other camp administrators, S.C. was caused

to suffer severe emotional distress as described herein, including panic attacks, night terrors, and

PTSD.

WHEREFORE, Plaintiffs demand damages against all Defendants, jointly and severally,

in an amount in excess of the prevailing arbitration limits, exclusive of pre-judgment interest, delay

damages and costs on all counts.

Respectfully Submitted,

KLINE & SPECTER

BY: Lorraine H. Donnelly /s/

THOMAS R. KLINE
DAVID K. INSCHO
LORRAINE H. DONNELLY
Date: 2/9/2022 Attorneys for Plaintiffs

23