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INTHE COURT OF COMMON PLEAS As. cP ‘CASenUilstns 2017 CV 0212 Docket: sosars12 Sheeony asnash Eee OF Coulee MonraoweRy COUNTY O40 MONTGOMERY COUNTY, OHIO JANE DOE I (A Pscudonym),individally) tnd as Guardian and Next Friend of| JANE DOE 2 (A Pseudonym),2 minor 5272 Susan Drive Dayton, Ohio 45415 and VERNON R. NORED, IL, individually Ad as Next Friend of SANE DOE 2 (A Pseudonym), & minor 1952 Elsmere Avenue Dayton, Ohio 45406 DAYTON PUBLIC SCHOOLS fo Iylian Guerrero 15 South Ludlow Dayton, Ohio 45402 and DAYTON BOARD OF EDUCATION clo Jylian Guerrero 115 South Ludlow Dayton, Ohio 45402 ond ADIL BAGUIROV 115 South Ludlow Dayton, Ohio 45402 and CASENO, Judge COMPLAINT (Gury Demand Endorsed Hereon) HAZEL ROUNDTREE 115 South Ludlow Dayton, Ohio 45402 and JOR LACEY 115 South Ludlow Dayton, Ohio 45402 and RONALD LEE 1S South Ludlow Dayton, Ohio 45402 and JOHN MCMANUS. 115 South Ludlow Dayton, Ohio 45402 and SHEILA TAYLOR 113 South Ludlow Dayton, Ohio $5402 and ROBERT WALKER 115 South Ludlow Dayton, Ohio 45402 and JANE AND JOHN DOE EMPLOYEES, a 115 South Ludlow Dayton, Ohio 45402 Defendants NOW COMES, Plaintifs Jane Doe I, Jane Doe 2, a minor, and Vernon Nored It (hereinafter refered to as “Plaintif"), by and through counsel, and for their Complaint states as fallows: FIRST CAUSE.OF ACTION (Nest 1d Gross 1. Atal ines relevant hers, Defendant Dayton Public Schools was anenity xtabished to adopt, implement, delegate andlor oversee procedures, tandans and gudetnes, including but not limited to insuring physica safety and well-being of students who atended the schools contained inthe Dayton Pabie Schools Distr, inctning Word of Wonder at Residence Park Schoo, chiding but not imi to recess and func activities on World of ‘Wonder playground premises and insuring that stents were adequately protected fom third party violence and ation 2 Atalltimes relevant herein, Defendant Dayton Board of Eaton was an entity ‘esablished to adopt, mpiement, delegate andior oversee procedures, standards and guidelines, including but not Tinted, insuring the physica sey and well-being of students wh atnded {he schools contained in Dayton Public Sooo Dist, inluding Word of Wonder at Residence Park Schoo, ineding bt not imied to recess ad funch activites on World of ‘Wonder playground premises, and insuring tat students were adequately protected from tind party violence and ation 3. Atalltimes relevant herein, Defendants Robeat C. Welker, Hazel Roundtes, Joe Lacey, Ronald Lee, John MeMans, Shela Taylor, and Adil Baguirov (berinatreoletively refered tas “Board Members) wer all Board Members of Defendant Board of Bducation and/or Defendant Dayton Publie Schools,