Upon information and belief, Defendant Alexander used school computers to upload,download, copy and distribute sexually deviant images of the children to a worldwide audienceof sexual degenerates and child-pornography enterprises.3.
Jane Doe was eight years old when Defendant Alexander began sexually abusingand filming her in school. Nevertheless, Jane Doe was brave enough to make her way to
Guidance Counselor, Defendant Linda Bradshaw, and report that she was beinginappropriately touched.4.
Defendant Bradshaw scolded
Jane Doe to “stop lying” and
commanded her to goback to Defendant
Defendant Bradshaw’s deliberate indifference to Jane Doe
violated no less than six explicit provisions of
Manual requiring her to protect Jane Doeby, at a minimum, reporting her allegations to the principal, superintendent, and policeauthorities. That, and other deliberate indifference, violated duties owed this young, vulnerablechild under federal and state law.5.
Denied help, Jane Doe continued to be sexually abused in unconscionable waysand filmed by Defendant Alexander in school.6.
Jane Doe, by her lawful guardian
, P.B., brings this civil action againstDefendants Board of Education, Bradshaw, John Roes 1-10, and Alexander for variousviolations of the Educational Amendments of 1972 (Title IX), 20 U.S.C. § 1981,
.; theFourteenth Amendment to the United States Constitution (under 42 U.S.C. § 1983); the NorthCarolina Constitution, and for other violations of North Carolina law.
This Court has subject matter jurisdiction over this matter pursuant to 28 U.S.C. §1331 because this litigation involves matters of federal law, including: claims made under the
Case 1:12-cv-00334 Document 1 Filed 10/22/12 Page 2 of 36