B.

ROBERT ALLARD (#175592)

1 LAUREN A. CERRI (#282524)
CERRI BOSKOVICH & ALLARD LLP
2 96 NORTH THIRD STREET, SUITE 620
SAN JOSE, CALIFORNIA 95112
3 (408) 289-1417
4 Fax: (408) 289-8127
rallard@cbalawfirm.com
5 lcerri@cbalawfirm.com

6 Attorneys for Plaintiff

7
8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF CONTRA COSTA
9
10 JANE DOE, Case No.
11 Plaintiff, COMPLAINT FOR DAMAGES
12 vs. (1) Sexual Assault of a Minor
13 (2) Negligent Hiring, Supervision
SAN RAMON VALLEY UNIFIED SCHOOL and/or Retention of Ryan Weible by
14 DISTRICT, RYAN WEIBLE, and DOES 3 District Employees [Government
through 30, inclusive, Code §815.2]
15 (3) Negligent Supervision of Plaintiff by
Defendants. District Employees [Government
16 Code §815.2]

17
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19 Plaintiff JANE DOE herein alleges:

20 COMMON ALLEGATIONS

21 1. Plaintiff JANE DOE [DOB: 11/04/1993], a California resident, brings this action

22 under a pseudonym due to the unusually sensitive nature of the childhood sexual assault

23 allegations in this complaint.

24 2. Defendant SAN RAMON VALLEY UNIFIED SCHOOL DISTRICT

25 [“DISTRICT”] is a public entity, a school district in the County of Contra Costa, charged with

26 the duty to implement various programs and procedures for the safe education of students

27 entrusted to its care, including students attending San Ramon Valley High School [“San Ramon

28 Valley”]. Pursuant to Government Code §905(m) and (p) and 935(f), Plaintiff is exempted from

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COMPLAINT FOR DAMAGES
 1 complying with the Government Claims Act requirements.
2 3. Defendant RYAN WEIBLE [“WEIBLE”], a California resident, was at all
3 relevant times employed by DISTRICT as a teacher and theatre director at San Ramon Valley.
4 4. In or about the 2010-2011 school year, while Plaintiff was a senior at San Ramon
5 Valley, WEIBLE used his position of trust and authority as a teacher to gain access to her and
6 sexually assault her on school grounds in the theatre room, the “green room”, his car, his
7 apartment, and in his office, as well as on a DISTRICT-sponsored trip.
8 5. Plaintiff is informed and believes and thereon alleges that, as of the 2009-2010
9 school year, DISTRICT knew, had reason to know, or was otherwise on notice that WEIBLE
10 engaged in highly inappropriate grooming behavior with his minor female students, including
11 Plaintiff, which created a risk he would sexually assault one of them including but not limited to:
12 giving side hugs and frontal hugs to minor females on school grounds, inviting female students
13 to spend time in his office alone, giving hand massages to female students, having minor female
14 students sit on his lap in his classroom and/or the theatre room, and making inappropriate and/or
15 sexual comments to minor female students. Other students witnessed WEIBLE interacting
16 inappropriately with minor females, including plaintiff, on school grounds, including giving them
17 long frontal hugs, having them sit on his lap, fraternizing with them in the parking lot after school
18 hours, and devoting special attention to particular female students.
19 6. Beginning in the 2009-2010 school year, WEIBLE used his position of trust and
20 authority to groom Plaintiff for his sexual advances. WEIBLE gave Plaintiff special attention
21 including buying plaintiff meals and gifts, spending time alone with Plaintiff in the windowless
22 theatre room multiple times a week behind a closed door, removing Plaintiff from her classes to
23 spend one-on-one time with her, transporting Plaintiff in his personal vehicle, giving written notes
24 to Plaintiff, and touching plaintiff inappropriately during school-sponsored events.
25 7. While Plaintiff was isolated in WEIBLE’s classroom and in the theatre room,
26 WEIBLE would sexually assault Plaintiff in various ways, including kissing, digital penetration
27 and sexual intercourse. On one occasion during the 2010-2011 school year, WEIBLE had
28 Plaintiff come to the theatre room on DISTRICT’s campus in the middle of the night wherein he

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COMPLAINT FOR DAMAGES
 1 sexually molested her. Upon entering the theatre room, the school’s alarm system was set off,
2 triggering a police response.
3 8. In the Summer of 2010, WEIBLE accompanied Plaintiff on a senior trip to New
4 York City, which was sponsored by DISTRICT. Plaintiff, the other senior students, and WEIBLE
5 stayed in a hotel in New York City. During this trip, WEIBLE sexually assaulted Plaintiff
6 numerous times including digitally penetrating plaintiff in her hotel room. Upon information and
7 belief, DISTRICT did not begin investigating any of WEIBLE’s inappropriate conduct until 2012.
8 9. The true names and/or capacities, whether individual, corporate, associate, or
9 otherwise, of defendants named herein as DOES 3 through 30, inclusive are unknown to Plaintiff
10 at this time, and Plaintiff therefore sues said defendants by such fictitious names. Plaintiff will
11 seek leave to amend this Complaint to allege their true names and capacities when the same have
12 been ascertained. Plaintiff is informed and believes and thereon alleges that each of the
13 defendants designated herein as DOES 3 through 30 are responsible in some manner or is
14 otherwise legally liable to Plaintiff for the injuries complained of herein.
15 10. At all times herein mentioned, each of the defendants was an agent, servant,
16 employee, partner, joint venturer, franchisee, alter ego, aider and abettor, and/or co-conspirator,
17 and engaged in a common or common enterprises with each of the remaining defendants herein,
18 and was at all relevant times acting within the course and scope of said agency, service,
19 employment, partnership, joint venture, franchise, unlawful enterprise, conspiracy and/or other
20 lawful or unlawful conduct as herein alleged.
21
FIRST CAUSE OF ACTION
22 Sexual Assault of a Minor
23 As and for a First Cause of Action, Plaintiff alleges against defendants RYAN WEIBLE,
24 and DOES 3 through 10 as follows:
25 11. Plaintiff hereby incorporates all paragraphs of her Common Allegations, as though
26 set forth in full herein.
27 12. As an employee of DISTRICT, WEIBLE was under a duty to refrain from
28 engaging in any harmful activity towards the students entrusted to DISTRICT’s care, including
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COMPLAINT FOR DAMAGES
 1 Plaintiff.
2 13. Commencing in 2009, WEIBLE used his position of trust and authority as a
3 teacher to groom Plaintiff for his sexual advances, exercise control over her person to comply
4 with his demands, and/or to sexually abuse Plaintiff including, inter alia, sexual intercourse.
5 14. As a legal result of the foregoing, Plaintiff was injured in health, strength and
6 activity, sustaining bodily injuries and shock and injury to her nervous system and person, all of
7 which caused and continue to cause Plaintiff great mental, physical and nervous pain and
8 suffering. Plaintiff has thereby sustained damages in an amount in excess of the minimum
9 jurisdictional limits of this court.
10 15. The acts of defendant WEIBLE perpetrated upon Plaintiff were intentional,
11 malicious, and/or oppressive, entitling Plaintiff to punitive damages against WEIBLE pursuant to
12 Civil Code §3294.
13 SECOND CAUSE OF ACTION
Negligent Hiring, Supervision, and/or Retention of WEIBLE by District Employees
14 [Government Code §815.2]
15 As and for a Second Cause of Action, Plaintiff alleges against SAN RAMON VALLEY
16 UNIFIED SCHOOL DISTRICT, and DOES 11 through 20, and each of them, as follows:
17 16. Plaintiff hereby incorporates all paragraphs of her Common Allegations and First
18 Cause of Action, as though set forth in full herein.
19 17. As a minor and student enrolled at San Ramon Valley, DISTRICT stood in a
20 special relationship with Plaintiff by which DISTRICT owed Plaintiff a duty to protect her
21 against, inter alia, sexual abuse by an employee during school hours on school grounds. Plaintiff
22 was entitled to a reasonably safe environment in which to learn, free from inappropriate exercise
23 of authority over her person, grooming behaviors, inappropriate touching, and sexual behaviors
24 from educators, staff, and others employed in a position of trust and authority over her at said
25 school. As such, DISTRICT’s employees owed Plaintiff a duty of care to, inter alia, properly
26 screen personnel, to properly supervise personnel, and to properly discipline personnel who
27 present a risk of harm to students.
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COMPLAINT FOR DAMAGES
 1 18. DISTRICT’s employees breached said duty owed to Plaintiff by, inter alia, failing
2 to properly screen WEIBLE, failing to properly supervise WEIBLE to detect and thereon
3 discipline WEIBLE for his grooming behaviors [such as his gifting to students, isolating students,
4 hugging minor female students, buying meals for students, making inappropriate comments to
5 students], failing to properly monitor WEIBLE’s office, failing to terminate WEIBLE, and failing
6 to train and/or educate DISTRICT’s employees on how to detect and deter teachers from engaging
7 in inappropriate grooming behavior with students.
8 19. As a legal result of the foregoing, Plaintiff was sexually assaulted and thereby
9 suffered physical, mental and emotional injuries, all to her general damages as hereinbefore
10 alleged.
11 THIRD CAUSE OF ACTION
Negligent Supervision of Plaintiff by District Employees
12 [Government Code §815.2]
13 As and for a Third Cause of Action, Plaintiff alleges against defendants SAN RAMON
14 VALLEY UNIFIED SCHOOL DISTRICT and DOES 21 through 30 as follows:
15 20. Plaintiff hereby incorporates all paragraphs of her Common Allegations and First
16 and Second Causes of Action, as though set forth in full herein.
17 21. DISTRICT owed a duty to protect plaintiff while she was entrusted to its care.
18 As Plaintiff was a student within DISTRICT, DISTRICT’s employees owed her a duty of care
19 to, inter alia, properly supervise Plaintiff to protect her from potential dangers while on school
20 grounds and to report any reasonable suspicion of child abuse to law enforcement and/or child
21 protective services.
22 22. DISTRICT’s employees breached said duties owed by failing to properly
23 supervise Plaintiff such that WEIBLE was allowed to openly groom and sexually assault Plaintiff
24 on school grounds and/or to transport Plaintiff in his personal vehicle wherein he sexually
25 assaulted her; by failing to detect WEIBLE isolating Plaintiff on school grounds after
26 instructional hours; failing to report a reasonable suspicion of child abuse by WEIBLE to law
27 enforcement and/or child protective services, failing to repudiate WEIBLE’s predatory behavior;
28 and failing to train and/or educate DISTRICT’s employees on how to effectively supervise it

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COMPLAINT FOR DAMAGES
 1 students.
2 23. As a legal result of the foregoing, Plaintiff was repeatedly sexually assaulted
3 and/or molested, and thereby suffered physical, mental and emotional injuries, all to her general
4 damages as hereinbefore alleged.
5
6 PRAYER
7 WHEREFORE, Plaintiff prays judgment as follows:
8 1. For general damages and other non-economic relief, according to proof;
9 2. For prejudgment interest, as allowed by law;
10 3. For punitive damages against defendant WEIBLE;
11 4. For costs of suit herein; and,
12 5. For such other and further relief as the court may deem fit and proper.
13
14 Dated: February 20, 2024 CERRI, BOSKOVICH & ALLARD LLP
15
16 By:
B. ROBERT ALLARD
17 LAUREN A. CERRI
18 Attorneys for Plaintiff

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COMPLAINT FOR DAMAGES