Complaint,Petition: JOHN DOE, BY AND THROUGH HIS GUARDIAN AD LITEM, JOAN DOE VS LOS ANGELES UNIFIED SCHOOL DISTRICT, A CALIFORNIA PUBLIC ENTITY, AND DOES 1 THROUGH 100, INCLUSIVE.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/15/2020 10:11 AM Sherri R. Carter, Executive Officer/Clerk of Court, by V. Delgadillo,Deputy Clerk

             1     George B. Pacheco, Esq. I CASt. Bar No. 109794
                   Law Offices of George B. Pacheco & Associates
            2      1453 West Beverly Boulevard
                   Montebello, California 90640
             3     (323)726-10821 F. (323)721-2563
                   general@gbp4law.com
             4
                   Attorney for Plaintiff:
             5
                   JOHN DOE, a minor, by and through
             6     his Guardian Ad Litem, JOAN DOE

             7
             8                                SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                    COUNTY OF LOS ANGELES, CENTRAL DISTRICT, UNLIMITED
             9
           10      JOHN DOE, a minor, by and through his                                    ) Case No.:     19STCV02750
                   Guardian Ad Litem, JOAN DOE,                                             ) (Assigned for All Purposes to----=D,-ep_a_rt-:-m-ent
                                                                                            )
           11                                                                                 SS5, Honorable Stephen Goorvitch)

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                                           Plaintiff(s),
                                                                                            ~    1st AMENDED COMPLAINT FOR
                                                                                                 DAMAGES FOR:
           13           vs.
                   LOS ANGELES UNIFIED SCHOOL                                               l    [Gov. Code §945.6]
                                                                                                   1. VIOLATION OF UNRUH CIVIL


                                                                                            l
           14      DISTRICT, a California public entity; and
                                                                                                      RIGHTS ACT
                   DOES 1 through 100, inclusive,                                                  2. VIOLATION OF EDUCATION
           15
                                                                                                      CODE§220
                                           Defendant(s)                                     )      3. NEGLIGENCE
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                                                                                            )      4. NEGLIGENT SUPERVISION
           17                                                                               )
                                                                                                            UNLIMITED
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                   COMES NOW Plaintiff JOHN DOE ("Plaintiff' or "John Doe"), a minor, by and through his
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                   Guardian Ad Litem, JOAN DOE ("JOAN DOE"), complains and alleges on information and
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                   belief the following against LOS ANGELES UNIFIED SCHOOL DISTRICT ("DEFENDANT"
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                   or "LAUSD") and DOES 1 through 100, inclusive (collectively, "DEFENDANTS"):
           22                                                                  INTRODUCTION
           23              1. This case arises out ofDEFENDANTS' hostile environment for special education
           24        students, including PLAINTIFF JOHN DOE, a middle school student.

           25             2. Over the course of PLAINTIFF's tenure as a student at DEFENDANT LAUSD's El

           26        Sereno Middle School ("ESMS"), other students subjected him to the horrors of harassment,
                     bullying, taunting, epithets, and subordination.
           27

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                                                                                           - 1-

                                                                    COMPLAINT FOR DAMAGES
                                                                        [Gov. Code §945.6]