BPS Transdev Complaint Via Morgan & Morgan

Date Filed 12/15/2023 10:07 AM
Superior Court - Suffolk

Docket Number
ER
COMMONWEALTH OF MASSACHUSETTS
SUFFOLK, ss. SUFFOLK SUPERIOR COURT
____________________________________
)
JANE DOE, individually and as Mother)
And Natural Guardian of her )
minor child, CHILD DOE )
Plaintiffs, ) CIVIL ACTION. NO.
)
v. )
)
TRANSDEV SERVICES, INC., )
THE MATCH FOUNDATION, INC., )
BOSTON PUBLIC SCHOOLS, )
CITY OF BOSTON, )
TRANSDEV BUS DRIVER, and )
TRANSDEV BUS MONITOR )
Defendants. )
____________________________________)
COMPLAINT AND DEMAND FOR JURY TRIAL
1. This action arises from a series of sexual assaults upon then nine-year-old Child Doe while
on her privately operated public-school bus. The sexual assaults occurred on diverse dates
over a period of seven (7) months and were committed by another student who was eleven-
years-old. The sexual assaults took place just a few feet from the bus monitor and the bus
driver on the ride home after school from the Match Charter Public School. This action is
brought to compensate Child Doe and her family for the suffering they have endured, and
will continue to endure, as a result of these sexual assaults, to hold accountable those
responsible for the safety of Child Doe and other students riding school buses each day,
and to prevent similar incidents from happening in the future.
PARTIES
2. Plaintiff, Jane Doe, individually and as a parent and natural guardian of her minor child,
Date Filed 12/15/2023 10:07 AM
Docket Number
Child Doe, resides in the County of Suffolk, Commonwealth of Massachusetts.
3. Plaintiff, Child Doe, resides with her Mother Jane Doe. Child Doe was nine-years-old at
the time of the sexual assaults.
4. Defendant, Transdev Services, Inc. (“Transdev”), is a foreign corporation, organized under
the laws of the State of Maryland, with a principal office located at 720 E. Butterfield Road,
Suite 300, Lombard, IL 60148, and a Registered Agent, CT Corporation located at 155
Federal Street, Sute 700, Boston, MA 02110. Transdev Services, Inc. conducts business
within the Commonwealth and maintains its usual place of business at 101 Federal Street,
Boston, Massachusetts 02110.
5. Defendant, The Match Foundation, Inc., operating as the Match Community Day Charter
Public School in Hyde Park, is a domestic nonprofit corporation with a principal office and
registered agent at 215 Forest Hills St., Jamaica Plain, Massachusetts 02130.
6. Defendant, Boston Public Schools, is a school district serving the City of Boston,
Massachusetts with a principal place of operation at 2300 Washington Street, Roxbury,
Massachusetts 02119.
7. Defendant, City of Boston, is a duly incorporated municipality of the Commonwealth of
Massachusetts, with a principal place of business at Boston City Hall, One City Hall
Square, Boston, Massachusetts, 02108. The City of Boston oversees the operation of the
Boston Public Schools.
8. Defendant, Transdev Bus Driver, whose identity is known to Plaintiffs via driver
identification number, has been withheld here for privacy purposes. Transdev Bus Driver
was the private, commercial bus driver of Child Doe’s school bus at all times relevant to
this Complaint.
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Docket Number
9. Defendant, Transdev Bus Monitor, whose identity is known to Plaintiffs but withheld here
for privacy purposes, resides in the County of Suffolk, Commonwealth of Massachusetts.
Transdev Bus Monitor was the private, commercial bus monitor of Child Doe’s school bus
at all times relevant to this Complaint.
JURISDICTION AND VENUE
10. The Massachusetts Superior Court has Jurisdiction over this matter, pursuant to M.G.L. c.
258 § 3. Venue in this form is proper, pursuant to M.G.L. c. 223 § 1.
FACTS
11. Plaintiffs incorporate by reference paragraphs 1-10 of this Complaint.
12. Defendant, The Match Foundation, Inc., founded, owns, operates, manages, oversees,
maintains, and/or is otherwise responsible for the Match Community Day Charter Public
School.
13. In September 2022, Child Doe began fourth grade at the Match Community Day Charter
Public School (hereinafter “the School”).
14. Like many children, Child Doe took the bus to School. Child Doe’s school bus that year
was Bus Number B530 (hereinafter “Transdev Bus”), which is owned and operated by
Transdev, driven by a Transdev employed bus driver, and monitored by a Transdev
employed bus monitor. The Transdev Bus route included Child Doe’s neighborhood in
Roxbury, Massachusetts. Students were picked up and bussed to and from the Charter
School, located at 100 Poydras Street, Hyde Park, Massachusetts 02136.
15. On each Transdev Bus ride, Child Doe sat in close proximity to the Transdev Bus Monitor,
who was responsible for monitoring and for the safety of the Transdev Bus child
passengers.
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16. On each ride, Transdev Bus Driver was also responsible for monitoring and for the safety
of the Transdev Bus child passengers.
17. Beginning in October 2022 of the 2022-2023 school year, nine-year-old Child Doe was
sexually assaulted numerous times by another student (hereinafter “the Perpetrator”) while
onboard the Transdev Bus. The sexual assaults occurred over a series of seven (7) months
and included numerous rapes and indecent assault and batteries. The sexual assaults all
occurred within a close proximity to Transdev Bus Monitor.
18. The Perpetrator repeatedly threatened Child Doe with physical violence if she ever reported
his sexual abuse.
19. On or about May 2, 2023, Defendant, The Match Foundation, Inc. became aware of the
sexual assaults against Child Doe. Child Doe disclosed the sexual assaults to two friends
who alerted staff at the School.
20. During the investigation that ensued, it was learned that Transdev requires this Transdev
Bus to have mandatory video equipment onboard; however, Transdev admitted that it
searched for video footage from the Transdev Bus and no video was located from the entire
period of sexual abuse between October 2022 and May 2023, despite specific request for
preservation in May 2023.
21. Defendant, The Match Foundation, Inc., Defendant Boston Public Schools, and/or
Defendant City of Boston were responsible for providing safe and secure, monitored,
transportation for the School’s students. The Match Foundation, Inc., Boston Public
Schools, and/or City of Boston contracted with Defendant Transdev to provide these
services. Transdev, an international transportation company, owned, and operated the
Transdev Bus on which Child Doe was sexually assaulted.
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22. Transdev interviewed, screened, hired, trained, retained, supervised, and managed
Defendant Transdev Bus Driver.
23. Transdev interviewed, screened, hired, trained, retained, supervised, and managed
Defendant Transdev Bus Monitor.
24. Transdev Bus Driver was responsible for the safety of the children who rode this Transdev
Bus. Transdev Bus Driver was responsible for monitoring and, when necessary, managing
student behavior on the Transdev Bus and had a duty to monitor the children on the
Transdev Bus. This duty included visually monitoring the children by use of the tools
provided by Transdev, such as video recording, and multiple interior mirrors installed for
this very purpose. It also included listening closely to all that went on within the Transdev
Bus. Transdev Bus Driver is specifically authorized and required to stop the Transdev Bus
as necessary in order to intercede and/or prevent behavior that is, or could become, unsafe.
Transdev Bus Driver also had a duty to affirmatively report any concerning behavior to
teachers and administrators at the School.
25. Transdev Bus Monitor was responsible for the safety of the children who rode this
Transdev Bus. Transdev Bus Monitor was responsible for monitoring and, when necessary,
managing student behavior on the Transdev Bus and had a duty to monitor the children on
the Transdev Bus. This duty included visually monitoring the children by use of the tools
provided by Transdev. It also included listening closely to all that went on within the
Transdev Bus. Transdev Bus Monitor is specifically authorized and required to instruct
Transdev Bus Driver to stop the Transdev Bus as necessary in order to intercede and/or
prevent behavior that is, or could become, unsafe. Transdev Bus Monitor also had a duty
to affirmatively report any concerning behavior to teachers and administrators at the
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School.
26. Transdev Bus Driver either knew, or reasonably should have known, of the repeated and
ongoing sexual abuse onboard this Transdev Bus. Transdev Bus Driver had an affirmative
duty to identify, intervene, and take steps to end and report the abuse as well as to take
reasonable steps to prevent it from reoccurring in the future. Transdev Bus Driver breached
this duty, endangering Plaintiff Child Doe and other children under Transdev Bus Driver’s
care.
27. Transdev Bus Monitor either knew, or reasonably should have known, of the repeated and
ongoing sexual abuse onboard this Transdev Bus. Transdev Bus Monitor had an affirmative
duty to identify, intervene, and take steps to end and report the abuse as well as to take
reasonable steps to prevent it from reoccurring in the future. Transdev Bus Monitor
breached this duty, endangering Plaintiff Child Doe and other children under Transdev Bus
Monitor’s care.
28. Defendants Transdev, The Match Foundation, Inc., Boston Public Schools, and/or City of
Boston jointly and/or individually, were responsible for the training and supervision of
Transdev Bus Driver to safely operate the Transdev Bus while also responsibly monitoring
and supervising its student-passengers.
Boston jointly and/or individually, were responsible for the training and supervision of
Transdev Bus Monitor to oversee and monitor the Transdev Bus in order to ensure the
safety and wellbeing of the Transdev Bus’s student passengers.
Boston jointly and/or individually, were aware or reasonably should have been aware that
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the Perpetrator committed multiple sexual assaults against Child Doe, but Defendants
failed to adequately and properly monitor the students on this Transdev Bus.
31. Transdev Bus Driver, Transdev Bus Monitor, Transdev, The Match Foundation, Inc.,
Boston Public Schools, and/or City of Boston’s negligence independently and/or in concert
with other Defendants’ negligence, caused Child Doe to suffer repeated sexual assaults,
including rapes and indecent assault and batteries, in addition to threats of violence, by the
Perpetrator, resulting in irreparable and permanent injuries that will impact her, and as a
result, her mother, for the remainder of their lives.
32. Plaintiff duly served full and detailed Presentment pursuant to G.L. c. 258 upon all
municipal agencies on May 10, 2023, but has not received a response within the time
provided by the statute.
COUNT I - NEGLIGENCE
Jane Doe, individually and as parent/natural guardian of Child Doe v.
Transdev Services, Inc.
33. Plaintiffs hereby incorporate by reference and reassert paragraphs 1-32 of this Complaint
as if set forth fully herein.
34. Defendant Transdev as owner and operator of the Transdev Bus and by and through
Defendants Transdev Bus Driver and Transdev Bus Monitor, owed Plaintiffs the highest
duty of care compatible with the practical performance of all of Transdev’s duties, to
protect Child Doe from foreseeable harm as she rode the Transdev Bus to and from School
and to warn about dangers faced by Child Doe and other students.
35. Defendant Transdev negligently hired, trained, retained, supervised, and/or managed
Transdev Bus Driver, as set forth above.
36. Defendant Transdev negligently hired, trained, retained, supervised, and/or managed
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Transdev Bus Monitor, as set forth above.
37. As a direct and proximate result of the negligence of Transdev, Plaintiffs suffered severe
physical, mental, and emotional injuries, extraordinary pain and suffering, loss of
enjoyment of life, and medical, psychological, financial, and economic damages. Plaintiffs,
and in particular Child Doe, will suffer extensive and continued such damages and will
require ongoing medical intervention and counseling assistance, potentially for the rest of
their lives.
WHEREFORE, Plaintiffs Jane Doe, individually and as Parent and Natural Guardian of
her minor child, Child Doe, demand judgment as against Defendant Transdev Services, Inc. in the
amount which will fairly and adequately compensate Plaintiffs, plus interest, costs, attorneys’ fees,
and any other relief as the Court may deem appropriate.
COUNT II - NEGLIGENCE
The Match Foundation, Inc.
39. Defendant The Match Foundation, Inc. as owner/operator of the School owed Plaintiffs a
duty of care to protect Child Doe from foreseeable harm as she rode the Transdev Bus to
and from School and to warn about dangers faced by Child Doe and other students.
40. Defendant The Match Foundation, Inc. operating as the School, negligently hired, trained,
retained, supervised, and/or managed Transdev Bus Driver, as set forth above.
41. Defendant The Match Foundation, Inc. operating as the School, negligently hired, trained,
retained, supervised, and/or managed Transdev Bus Monitor, as set forth above.
42. Defendant The Match Foundation, Inc. operating as the School, also failed to warn parents,
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or anyone else about the Perpetrator’s behavior.
43. As a direct and proximate result of the negligence of The Match Foundation, Inc., Plaintiffs
suffered severe physical, mental, and emotional injuries, extraordinary pain and suffering,
loss of enjoyment of life, and medical, psychological, financial, and economic damages.
Plaintiffs, and in particular Child Doe, will suffer extensive and continued such damages
and will require ongoing medical intervention and counseling assistance, potentially for
the rest of their lives.
her minor child, Child Doe, demand judgment as against Defendant The Match Foundation, Inc.
in the amount which will fairly and adequate compensate Plaintiffs, plus interest, costs, attorneys’
fees, and any other relief as the Court may deem appropriate.
COUNT III - NEGLIGENCE

Boston Public Schools and the City of Boston
45. Defendants Boston Public Schools and the City of Boston, responsible for arranging
transportation services for the School, owed Plaintiffs a duty of care to protect Child Doe
from foreseeable harm as she rode the Transdev Bus to and from School and to warn about
dangers faced by Child Doe and other students.
46. Defendants Boston Public Schools and the City of Boston negligently contracted with,
hired, trained, retained, supervised, and/or managed Transdev Bus Driver, as set forth
above.
47. Defendants Boston Public Schools and the City of Boston negligently contracted with,
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hired, trained, retained, supervised, and/or managed Transdev Bus Monitor, as set forth
above.
48. Defendants Boston Public Schools and the City of Boston also failed to warn parents, or
anyone else about the Perpetrator’s behavior.
49. As a direct and proximate result of the negligence of Defendants Boston Public Schools
and the City of Boston, Plaintiffs suffered severe physical, mental, and emotional injuries,
extraordinary pain and suffering, loss of enjoyment of life, and medical, psychological,
financial, and economic damages. Plaintiffs, and in particular Child Doe, will suffer
extensive and continued such damages and will require ongoing medical intervention and
counseling assistance, potentially for the rest of their lives.
her minor child, Child Doe, demand judgment as against Defendants Boston Public Schools and
the City of Boston in the amount which will fairly and adequate compensate Plaintiffs, plus
interest, costs, attorneys’ fees, and any other relief as the Court may deem appropriate.
COUNT IV – NEGLIGENCE – VICARIOUS LIABILITY

Transdev Services, Inc., The Match Foundation, Inc.,
Boston Public Schools, and the City of Boston
51. Each Defendant-entity (against whom individual counts are hereby pled as “Count IV(A)”,
“Count IV(B),” etc.), independently and/or in concert with other Defendants, controlled
and/or had a right to control the contracting with, hiring, training, assignment, and/or
supervision of bus drivers and/or monitors responsible for providing safe transportation
services for the School’s students and for warning about dangers to students using that
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transportation:
A. Transdev Services, Inc.

B. The Match Foundation, Inc.
C. Boston Public Schools
D. City of Boston
52. Defendant Transdev Bus Driver was acting within the course and scope of their
employment with Defendant Transdev under contract with Defendant The Match
Foundation, Inc., Defendant Boston Public Schools, and/or Defendant City of Boston,
when Transdev Bus Driver’s negligent conduct and/or willful disregard for the safety of
Child Doe caused Child Doe’s injuries.
53. As a direct and proximate result of the negligence of Defendants Transdev Services, Inc.,
The Match Foundation, Inc., Boston Public Schools, and the City of Boston, Plaintiffs
her minor child, Child Doe, demand judgment as against Defendants Transdev Services, Inc., The
Match Foundation, Inc., Boston Public Schools, and the City of Boston in the amount which will
fairly and adequate compensate Plaintiffs, plus interest, costs, attorneys’ fees, and any other relief
as the Court may deem appropriate.
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COUNT V – NEGLIGENCE – VICARIOUS LIABILITY

Transdev Services, Inc., The Match Foundation, Inc.,
Boston Public Schools, and the City of Boston
55. Each Defendant-entity listed below (against whom individual counts are hereby pled as
“Count V(A)”, “Count V(B),” etc.), independently and/or in concert with other Defendants,
controlled and/or had a right to control the contracting with, hiring, training, assignment,
and/or supervision of bus drivers and/or monitors responsible for providing safe
transportation services for the School’s students and for warning about dangers to students
using that transportation:
A. Transdev Services, Inc.

B. The Match Foundation, Inc.
C. Boston Public Schools
D. City of Boston
56. Defendant Transdev Bus Monitor was acting within the course and scope of their
employment with Defendant Transdev under contract with Defendant The Match
Foundation, Inc., Defendant Boston Public Schools, and/or Defendant City of Boston,
when Transdev Bus Monitor’s negligent conduct and/or willful disregard for the safety of
Child Doe caused Child Doe’s injuries.
57. As a direct and proximate result of the negligence of Defendants Transdev Services, Inc.,
The Match Foundation, Inc., Boston Public Schools, and the City of Boston, Plaintiffs
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her minor child, Child Doe, demand judgment as against Defendants Transdev Services, Inc., The
Match Foundation, Inc., Boston Public Schools, and the City of Boston in the amount which will
fairly and adequate compensate Plaintiffs, plus interest, costs, attorneys’ fees, and any other relief
as the Court may deem appropriate.
COUNT VI - NEGLIGENCE
Transdev Bus Driver
59. Defendant Transdev Bus Driver, the bus driver of Child Doe’s Transdev Bus and employee
of Transdev, at all relevant times in this Complaint, owed Plaintiffs a duty of care to protect
Child Doe from foreseeable harm as she rode the Transdev Bus to and from School and to
warn about known dangers she may face.
60. Defendant Transdev Bus Driver breached this duty of care owed to Plaintiffs, as set forth
above.
61. As a direct and proximate result of the negligence of Defendant Transdev Bus Driver,
Plaintiffs suffered severe physical, mental, and emotional injuries, extraordinary pain and
suffering, loss of enjoyment of life, and medical, psychological, financial, and economic
damages. Plaintiffs, and in particular Child Doe, will suffer extensive and continued such
damages and will require ongoing medical intervention and counseling assistance,
potentially for the rest of their lives.
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her minor child, Child Doe, demand judgment as against Defendant Transdev Bus Driver in the
amount which will fairly and adequate compensate Plaintiffs, plus interest, costs, attorneys’ fees,
COUNT VII - NEGLIGENCE

Transdev Bus Monitor
62. Plaintiffs hereby incorporate by reference and reasserts paragraphs 1-61 of this Complaint
63. Defendant Transdev Bus Monitor, the bus monitor of Child Doe’s Transdev Bus and
employee of Transdev, at all relevant times in this Complaint, owed Plaintiffs a duty of
care to protect Child Doe from foreseeable harm as she rode the Transdev Bus to and from
School and to warn about known dangers she may face.
64. Defendant Transdev Bus Monitor breached this duty of care owed to Plaintiffs, as set forth
above.
65. As a direct and proximate result of the negligence of Defendant Transdev Bus Monitor,
Plaintiffs suffered severe physical, mental, and emotional injuries, extraordinary pain and
suffering, loss of enjoyment of life, and medical, psychological, financial, and economic
damages. Plaintiffs, and in particular Child Doe, will suffer extensive and continued such
damages and will require ongoing medical intervention and counseling assistance,
potentially for the rest of their lives.
her minor child, Child Doe, demand judgment as against Defendant Transdev Bus Monitor in the
amount which will fairly and adequate compensate Plaintiffs, plus interest, costs, attorneys’ fees,
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COUNT VIII – LOSS OF CONSORTIUM

Jane Doe v. Transdev Services, Inc., The Match Foundation, Inc., Boston Public Schools,
the City of Boston, Transdev Bus Driver, and Transdev Bus Monitor
67. As a direct and proximate result of each Defendants’ separate and independent negligence,
whether acting individually and/or in concert, Plaintiff Jane Doe lost the unimpaired care,
comfort, solace, moral support, assistance, society, and companionship of her child, Child
Doe.
WHEREFORE, Plaintiff Jane Doe demands judgment as against Defendants Transdev
Services, Inc., The Match Foundation, Inc., Boston Public Schools, the City of Boston, Transdev
Bus Driver, and Transdev Bus Monitor in the amount which will fairly and adequate compensate
Plaintiff Jane Doe, plus interest, costs, attorneys’ fees, and any other relief as the Court may deem
appropriate.
COUNT IX – SPOLIATION OF EVIDENCE

Jane Doe, individually and as parent/natural guardian of Child Doe v. Any and All
Responsible Defendants
69. Defendant Transdev and/or its co-Defendants, negligently, recklessly, and/or intentionally
lost or destroyed video footage from the Transdev Bus which would have shown the
interior of the Transdev Bus during times relevant to the allegations in this Complaint.
70. Defendant(s) was (were) made aware of sexual assaults that took place onboard the
Transdev Bus and, yet, failed to secure, retrieve, protect, maintain, and safely keep
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evidence directly relevant to this matter. Moreover, Defendant(s) had been promptly given
notice by Plaintiffs and were specifically asked to preserve all video footage. Therefore,
Defendant(s) was(were) aware and/or reasonably should have been aware that video
footage of this matter was considered highly relevant to this action.
71. On May 22, 2023, Plaintiffs were advised that Defendant Transdev had searched for the
requested video footage from the Transdev Bus and none was located.
her minor child, Child Doe, pray that this Court issue sanctions as to all responsible parties for the
spoliation of evidence, including but not limited to holding responsible Defendants in default,
striking defenses that responsible Defendants seek to assert, limiting or precluding evidence that
the responsible Defendants seek to offer, instructing the jury at trial that such evidence must be
presumed to have been helpful to Plaintiffs, or to issue appropriate sanctions or remedies that the
Court deems appropriate. Plaintiffs further pray that this Court issue any orders reasonable and
appropriate for further preservation, handling, examination, and/or testing of any video,
documents, or evidence relevant to this matter.
JURY DEMAND
The Plaintiffs hereby demand a trial by jury on each claim asserted, and on each defense
so triable, asserted at any time by any current or future-named defendants, and Plaintiffs make
further demand for attorney-conducted voir dire to the greatest extent permissible.
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Respectfully submitted,
The Plaintiffs,
JANE DOE, individually and as Mother and
Natural Guardian of her minor child, CHILD DOE,
Nina M. Bonelli, BBO#: 698709

Alexander L. Zodikoff, BBO#: 698670
Keith Mitnik, Pro Hac Vice Forthcoming
Morgan & Morgan
155 Federal Street, Suite 1502
Boston, MA 02110
T: 857-383-4902
F: 857-383-4927
NBonelli@forthepeople.com
Dated: December 14, 2023 AZodikoff@forthepeople.com
17

BPS Transdev Complaint Via Morgan & Morgan

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Date Filed 12/15/2023 10:07 AM

Superior Court - Suffolk

SUFFOLK, ss. SUFFOLK SUPERIOR COURT

COMPLAINT AND DEMAND FOR JURY TRIAL

and to prevent similar incidents from happening in the future.

Child Doe, resides in the County of Suffolk, Commonwealth of Massachusetts.

the time of the sexual assaults.

4. Defendant, Transdev Services, Inc. (“Transdev”), is a foreign corporation, organized under

Boston, Massachusetts 02110.

Massachusetts with a principal place of operation at 2300 Washington Street, Roxbury,

7. Defendant, City of Boston, is a duly incorporated municipality of the Commonwealth of

Boston Public Schools.

for privacy purposes, resides in the County of Suffolk, Commonwealth of Massachusetts.

at all times relevant to this Complaint.

JURISDICTION AND VENUE

258 § 3. Venue in this form is proper, pursuant to M.G.L. c. 223 § 1.

11. Plaintiffs incorporate by reference paragraphs 1-10 of this Complaint.

Public School (hereinafter “the School”).

Transdev, driven by a Transdev employed bus driver, and monitored by a Transdev

School, located at 100 Poydras Street, Hyde Park, Massachusetts 02136.

of the Transdev Bus child passengers.

occurred within a close proximity to Transdev Bus Monitor.

his sexual abuse.

who alerted staff at the School.

preservation in May 2023.

services. Transdev, an international transportation company, owned, and operated the

Transdev Bus on which Child Doe was sexually assaulted.

Defendant Transdev Bus Driver.

Defendant Transdev Bus Monitor.

teachers and administrators at the School.

to affirmatively report any concerning behavior to teachers and administrators at the

and supervising its student-passengers.

safety and wellbeing of the Transdev Bus’s student passengers.

result, her mother, for the remainder of their lives.

provided by the statute.

as if set forth fully herein.

Transdev Bus Driver, as set forth above.

Transdev Bus Monitor, as set forth above.

and any other relief as the Court may deem appropriate.

as if set forth fully herein.

or anyone else about the Perpetrator’s behavior.

the rest of their lives.

COUNT III - NEGLIGENCE

as if set forth fully herein.

dangers faced by Child Doe and other students.

anyone else about the Perpetrator’s behavior.

counseling assistance, potentially for the rest of their lives.

COUNT IV – NEGLIGENCE – VICARIOUS LIABILITY

as if set forth fully herein.

A. Transdev Services, Inc.

Child Doe caused Child Doe’s injuries.

the rest of their lives.

as the Court may deem appropriate.

COUNT V – NEGLIGENCE – VICARIOUS LIABILITY

as if set forth fully herein.

using that transportation:

A. Transdev Services, Inc.

Child Doe caused Child Doe’s injuries.

the rest of their lives.

as the Court may deem appropriate.

as if set forth fully herein.

warn about known dangers she may face.

potentially for the rest of their lives.